1927ss09

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal), EPA ICR Number 1927.09, OMB Control Number 2060-0451.

1(b) Short Characterization/Abstract

The Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) were proposed on November 30, 1999; and promulgated on December 1, 2000. The emission guidelines were amended on February 7, 2013. The EPA later proposed to reconsider provisions of the 2013 final revisions to the emission guidelines for commercial and industrial solid waste incineration (CISWI) units (80 FR 3018, January 21, 2015), and took final action on that proposal on June 23, 2016 (81 FR 40956). Following promulgation of the 2016 CISWI rule, the EPA proposed to clarify various issues with implementation of these standards and certain testing and monitoring issues and inconsistencies within the rules. On June 15, 2018, the EPA proposed amendments to several provisions of the 2016 CISWI rule to address these issues (83 FR 28068). These revisions were published in the Federal Register on April 16, 2019 (84 FR 15846). Burdens associated with the 2013, 2016, and 2019 standards are addressed separately under EPA ICR Number 2385.08, and there is no additional burden associated with these revisions included in this ICR. This ICR applies only to those existing sources that have burdens under the 2000 standards. These regulations apply to sources commencing construction either on or before June 4, 2010, or to sources commencing modification or reconstruction between June 1, 2001, and August 7, 2013. The guidelines do not apply directly to CISWI unit owners and operators, since they are implemented through state implementation plans (SIP). If a state does not develop, adopt, and submit an approved state plan, or if a state’s plan is not approved, the EPA must promulgate a Federal implementation plan to implement the emission guidelines in a state without its own SIP. This information is being collected to assure compliance with 40 CFR Part 60, Subpart DDDD.

In general, all emission guidelines 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 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 required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. In the event that there is no such delegated authority, the EPA regional office can review them. All other 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 EPA regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator. 

The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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 for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). There are approximately 74 owners and operators of CISWI units, which are owned and operated by private industry. None of the 74 facilities in the United States are owned by state, local, tribal or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond.

Based on our consultations with industry representatives, there are an average of 1.4 affected facilities at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 74 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.

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; . . . .

In the Administrator's judgment, emissions from CISWI units either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the emission guidelines were promulgated for this source category at 40 CFR Part 60, Subpart DDDD.

2(b) Practical Utility/Users of the Data

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

The notifications required in these standards 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 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.

Additionally, the EPA is requiring electronic reporting for certain notifications or reports. The EPA is requiring that owners or operators of affected sources would submit electronic copies of initial, annual, and deviation reports; performance test reports; and results of CEMS performance evaluations through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI).

CEDRI includes the Electronic Reporting Tool (ERT) software, which is used by facilities to generate electronic reports of performance tests. The EPA is also requiring that 40 CFR Part 60, Subpart DDDD performance test reports and results of CEMS performance evaluations be submitted through the EPA’s ERT.

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

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

3(a) Non-duplication

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, 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 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 (87 FR 20847) on April 8, 2022. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 74 respondents will be subject to these same standards over the three-year period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the National Waste & Recycling Association, at 800-424-2869, and the Energy Recovery Council, at 202-467-6240.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for 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 that emission limitations are met. If the information required by these same 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 these standards. The 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. The EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing these violators due to either the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and operators of CISWI units. 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 for facilities with CISWI units may be found in the table below:

Standard (40 CFR Part 60, Subpart DDDD)	SIC Codes	NAICS Codes
Chemical Manufacturing	28	325
Electrical Equipment, Appliance, and Component Manufacturing	36	335
Wood Product Manufacturing	24	321
Furniture and Related Product Manufacturing	25	337
Justice, Public Order, and Safety Activities	9229	922
National Security and International Affairs	9711, 9721	928
Research Centers (colleges, universities, and professional schools)	8221	6113

4(b) Information Requested

(i) Data Items

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

State/US protectorates must perform the following requirements:

Requirement
Submit a state plan	§60.2505(a)
Submit a negative declaration	§60.2510

A source must make the following reports:

Notifications
Notification of construction/reconstruction.	§60.2790(a), §60.7(a)(1)
Notification of initial startup date.	§60.2790(a), §60.7(a)(3)
Notification of physical or operational change.	§60.2790(a), §60.7(a)(4)
Notification of demonstration date of continuous monitoring system performance.	§60.2790(a), §60.7(a)(5)
Notification of anticipated date for conducting opacity observations.	§60.2790(a), §60.7(a)(6)
Notification of use of continuous opacity monitoring system data results to determine compliance with opacity standard during performance testing.	§60.2790(a), §60.7(a)(7)
Notification of final control plan.	§60.2575(a), §60.2600(a), §60.2815(a)
Notification of final compliance.	§60.2575(b), §60.2585(a), §60.2815(b)
Notifications until increments of progress are met.	§60.2595, §60.2825(a) §60.2835
Notification of closure.	§60.2615, §60.2855
Qualified operator deviation notification.	§60.2785(a)(1)
Qualified operator deviation notification of resumed operation.	§60.2785(b)
Notification of waste-to-fuel switch.	§60.2710(a)(4), §60.2790(b)
Notification of air curtain incinerator closure.	§60.2855

Reports
Waste management plan.	§60.2755
Initial and subsequent performance test reports (electronic submission).	§§60.2760(a)-(c)
Annual report.	§60.2765, §§60.2770(a)-(p)
Emission limitation or operating limit deviation report.	§§60.2775(a)-(b), §§60.2780(a)-(d)
Qualified operator deviation status report.	§60.2785(a)(2)
Initial and annual opacity test reports for air curtain incinerators.	§60.2870

A source must keep the following records:

Recordkeeping
Maintain an onsite copy of the final control plan	§60.2600(b)
Maintain records of startups, shutdowns, or malfunctions.	§60.7(b)
Retain records for five years.	§60.2740
Maintain calendar date of each record.	§60.2740(a)
Maintain records of operating parameters.	§60.2740(b)
Maintain records of dates when deviation from operating limits has occurred, including reasons for deviations and descriptions of corrective actions taken.	§60.2740(e)
Maintain records of initial, annual, and any subsequent performance tests.	§60.2740(f)
Maintain records of CISWI unit operators who have completed the operator training requirements.	§§60.2740(g)-(h)
Maintain records of phone and/or pager numbers of CISWI unit operators having met the operator qualification criteria.	§60.2740(i)
Maintain records of monitoring device calibrations.	§60.7(f), §60.2740(j)
Maintain records of equipment vendor specifications and operation and maintenance requirements for incinerators, emission controls, and monitoring equipment.	§60.2740(k)
Maintain records of site-specific procedures; CISWI unit operator review of site-specific procedures; and operator training documentation and contact information.	§60.2660(a), §60.2740(l), §60.2660(c), §60.2740(g)
Maintain records of daily log of quantity and types of waste burned.	§60.2740(m)
Maintain records of annual inspections of air pollution control devices, any required maintenance, and any repairs not completed within the established timeframe.	§60.2740(n)
Maintain records of continuous monitoring systems parameter measurements.	§60.7(f), §60.2740(o)
Maintain records indicating date, time, and duration of bypass stack use.	§60.2740(p)
Maintain annual records showing previous stack test emission was below 75 percent of applicable limit and that no source operation changes occurred that would increase emissions within the past year.	§60.2740(q)
Maintain records of occurrence and duration of process equipment, air control, or monitoring equipment malfunctions.	§60.2740(r)
Maintain records of all required maintenance performed on air pollution control and monitoring equipment.	§60.2740(s)
Maintain records of actions taken to minimize emissions from process, air pollution control, and monitoring equipment during periods of malfunction.	§60.2740(t)
Maintain records showing how non-hazardous secondary materials meet legitimacy criteria or petition process requirements or showing how materials are listed as non-wastes.	§60.2740(u)
Maintain records of criteria establishing unit qualification as a small power production facility, and that proposed waste materials are homogeneous.	§60.2740(v)
Maintain records of criteria establishing unit qualification as a cogeneration facility, and that proposed waste materials are homogeneous.	§60.2740(w)
Records of initial and annual opacity tests for air curtain incinerators.	§60.2870(a)

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.

The rule was amended to include electronic reporting provisions on February 7, 2013. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application, rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts. Respondents are also required to submit electronic copies of notifications and certain reports through EPA’s CEDRI. The notification is an upload of their currently-required notification in portable document format (PDF) file. For purposes of this ICR, it is assumed that there is no additional burden associated with the proposed requirement for respondents to submit the notifications and reports electronically.

Electronic copies of records may also be maintained in order to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for Cd, CO, dioxins/furans, HCl, Pb, Hg, NO_x, PM, SO₂, and ash.

Perform initial performance test, Reference Method 1, 3A or 3B, 5, 6 or 6C, 7 or 7E, 9, 10, 10A, or 10B, 19, 22, 23, 26 or 26A, 29 or 30B, 321, or ASTM D6784-02 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 collecting, validating, and verifying information.

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

Develop, acquire, install, and utilize technology and systems for 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

The 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 the 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 these emission standards 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. The 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

The 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 these regulations. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown at the end of this document in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of ‘Burden’ under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor 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 16,100 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, 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 $157.61 ($75.05 + 110%)

Technical $123.94 ($59.02 + 110%)

Clerical $62.52 ($29.77 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.

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

The type of industry costs associated with the information collection activities in the subject standard(s) 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(s) and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Wet scrubber a	$3,423	0	$0	$0	0	$0
Annual stack testing b	$0	0	$0	$15,493	74	$1,146,445
Continuous parameter monitoring (including bypass stack) c	$0	0	$0	$322	74	$23,828
		Total	$0		Total d	$1,170,000

^a Total capital cost of parameter monitoring for wet scrubbers minus planning and equipment selecting cost equals: $18,786 - $800 = $17,986. Based on 0.11746 capital recovery factor, 10 percent interest rate, and 20 year lifetime of the units = $2,113 (1994 dollars); Costs have been increased from 1994 to 2020 $ using the CEPCI Equipment Cost Index: $2,113 x 1.62 cost adjustment = $3,423.

^b Assume 125 contractor hours per respondent and an average contractor labor rate of $123.94 per hour. The labor rate is based on the United States Department of Labor, Bureau of Labor Statistics, Sept 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.

^c Based on the memorandum titled "Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61,IV-B-66)," O&M cost = $1,693 x 0.11746 = $199 (1994 dollars); Costs have been increased from 1994 to 2020 $ using the CEPCI Equipment Cost Index. $199 x 1.62 cost adjustment = $322.

^d 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 $1,170,000. 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 $1,170,000. These are the 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. The EPA's overall compliance and enforcement program includes such activities 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 $45,200.

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

Managerial $70.56 (GS-13, Step 5, $44.10 + 60%)

Technical $52.37 (GS-12, Step 1, $32.73 + 60%)

Clerical $28.34(GS-6, Step 3, $17.17 + 60%)

These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 74 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 74 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	74	0	0	74
2	0	74	0	0	74
3	0	74	0	0	74
Average	0	74	0	0	74

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 74.

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 plans	0	1	0	0
Construction/reconstruction notification	0	1	0	0
Startup notification	0	1	0	0
Demonstration date of continuous monitoring system performance notification	0	1	0	0
Anticipated date for conducting opacity observations notification	0	1	0	0
Use of continuous opacity monitoring system data notification	0	1	0	0
Final control plan notification	0	1	0	0
Final compliance notification	0	1	0	0
Waste management plan	0	1	0	0
Initial performance test report	0	1	0	0
Annual report a	74	1	0	74
Semiannual report of emissions/parameter exceedances b	7.4	2	0	14.8
Status report for operators that are off-site for more than 2 weeks c	7.4	1	0	7.4
Corrective action summary for operators that are off-site for more than 2 weeks c	7.4	2	0	14.8
Qualified operator deviation notification of resumed operation c	7.4	1	0	7.4
			Total (rounded) d	118

^a Annual reports are not required until the second year that units are in operation; therefore, annual reports will only apply to existing sources (i.e., 74 respondents).

^b We assume that 10 percent of the facilities will have an exceedance during the year.

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

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

The number of Total Annual Responses is 118.

The total annual labor costs are $1,940,000. Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

(i) Respondent Tally

The total annual labor hours are 16,100 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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 136 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,170,000. 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 885 labor hours at a cost of $45,200; see below in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (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 burden from the most-recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. 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 this industry is very low or non-existent, so there is no significant change in the overall burden. There is a slight increase in costs, which is wholly due to the use of updated labor rates. This ICR uses labor rates from the most-recent Bureau of Labor Statistics report (September 2021) to calculate respondent burden costs.

There is a slight increase in the capital and O&M costs due to an adjustment to the estimated cost per respondent to reflect 2020 dollars using the Chemical Engineering Plant Cost Index (CEPCI) Equipment Cost Index and the use of updated labor rates for continuous parameter monitoring from the most-recent Bureau of Labor Statistics report (September 2021).

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 136 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor 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-OAR-2022-0025. 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), WJC 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. 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-OAR-2022-0025 and OMB Control Number 2060-0451 in any correspondence.

Part B of the Supporting Statement

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

Table 1: Annual Respondent Burden and Cost – Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)

Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year	Clerical hours per year	Total cost per year ($) b
			(C=AxB)			(F=Ex0.05)	(G=Ex0.10)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c, d	16	1	16	74	1,184	59.2	118	$163,477.84
B. Required Activities
1) Initial requirements e
a) Initial stack test and report	16	1	16	0	0	0	0	$0
b) Establish and teach operator qualification course	64	1	64	0	0	0	0	$0
c) Obtain operator qualification	72	1	72	0	0	0	0	$0
d) Establish operating parameters (maximum and minimum)	160	1	160	0	0	0	0	$0
e) Continuous parameter monitoring initial costs (including by-pass stack) f	9	1	9	0	0	0	0	$0
2) Periodic requirements
a) Annual stack test and test report (PM, HCl, and opacity)	12	1	12	74	888	44.4	88.8	$122,608.38
b) Annual refresher operator training course	12	1	12	74	888	44.4	88.8	$122,608.38
c) Annual review of site-specific information	8	1	8	74	592	29.6	59.2	$81,738.92
d) Continuous parameter monitoring (including by-pass stack) annual costs g	83	1	83	74	6,142	307	614	$848,041.30
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Control plan	40	1	40	0	0	0	0	$0
2) Notification of final compliance	4	1	4	0	0	0	0	$0
3) Report of initial performance test	8	2	16	0	0	0	0	$0
4) Siting analysis for new units only (establishes values for site-specific operating parameters)	8	1	8	0	0	0	0	$0
5) Waste management plan	160	1	160	0	0	0	0	$0
6) Annual Report h
a) Site-specific operating parameters	8	1	8	74	592	29.6	59.2	$81,738.92
b) Emissions/parameter exceedances and malfunctions	See 3E.10
c) Results of stack tests conducted during the year	See 3B
d) Statement of no exceedances i	8	1	8	66.6	533	26.6	53.3	$73,565.03
e) Documentation of use of by-pass stack	See 3B
f) Documentation for periods when all qualified operators were unavailable for more than 8 hours	8	1	8	74	592	29.6	59.2	$81,738.92
7) Status report for operators that are off-site for more than 2 weeks j	8	1	8	7.4	59	2.96	5.92	$8,173.89
8) Corrective action summary for operators that are off-site for more than 2 weeks j	8	2	16	7.4	118	5.92	11.8	$16,347.78
9) Qualified operator deviation notification of resumed operation	8	1	8	7.4	59.2	2.96	5.92	$8,173.89
10) Semiannual report of emissions/parameter exceedances i	12	2	24	7.4	178	8.88	17.8	$24,521.68
Subtotal for Reporting Requirements					13,599			$1,632,735
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c, d	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record Information
1) Records of operating parameters	See 3B
2) Records of periods for which minimum amount of data on operating parameters were not obtained	0.5	52	26	7.4	192	9.62	19.2	$26,565.15
3) Records of malfunction of the unit	1.5	1	1.5	7.4	11.1	0.56	1.11	$1,532.60
4) Records of exceedances of operating parameters	1.5	1	1.5	7.4	11.1	0.56	1.11	$1,532.60
5) Records of stack tests	See 3E
6) Records of persons who have reviewed operating procedures	1	1	1	74	74	3.7	7.4	$10,217.37
7) Records of persons who have completed operator training	1	1	1	74	74	3.7	7.4	$10,217.37
8) Records of persons who meet operator qualification criteria	1	1	1	74	74	3.7	7.4	$10,217.37
9) Records of monitoring device calibration	See 3B
10) Records of site-specific documentation	24	1	24	74	1,776	88.8	178	$245,216.76
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					2,544			$305,499
Total Labor Burden and Costs (rounded) k					16,100			$1,940,000
Total Capital and O&M Cost (rounded) k								$1,170,000
Grand Total (rounded) k								$3,110,000
Assumptions:
a We estimate that an average of 74 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates for privately-owned sources: $157.61 for managerial, $123.94 for technical, and $62.52 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We assume that all respondents will have to familiarize themselves with the regulatory requirements each year.
d Cost is incurred by a facility regardless of the number of affected units at the plant.
e This activity is based on a one-time cost only.
f Based on the “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61,IV-B-66)," we assume 9 hours (($300 for planning + $500 for selection)/$89.94 per hour = 9 hours).
g Based on the "Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions (A-91-61, IV-B-66)," respondents spend 83 hours for reporting.
h Respondents make one combined annual report per year.
i We assume that 10 percent of the facilities will have an exceedance during the year. The remaining 90% of facilities would submit a statement of no exceedance.
j Assume that 10 percent of facilities will not have a qualified operator available for more than two weeks at least once a year, and that two corrective action summaries will be required.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)

Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CXD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications	N/A
2. Familiarize with regulatory requirements	16	1	16	0	0	0	0	$0
3. Required Activities
Report Reviews
1) Review control plan	8	1	8	0	0	0	0	$0
2) Review notification of final compliance	8	1	8	0	0	0	0	$0
3) Review waste management plan	8	1	8	0	0	0	0	$0
4) Review initial stack test report	40	1	40	0	0	0	0	$0
5) Review annual compliance report	8	1	8	74	592	29.6	59.2	$34,769
6) Review semi-annual excess emission and parameter exceedance report c	8	2	16	7.4	118.4	5.92	11.84	$6,954
7) Review status report for operators that are off-site for more than 2 weeks d	2	1	2	7.4	14.8	0.74	1.48	$869
8) Corrective action summary for operators that are off-site for more than 2 weeks d	2	2	4	7.4	29.6	1.48	5.92	$1,738
9) Qualified operator deviation notification of resumed operation	2	1	2	7.4	14.8	0.74	1.48	$869
TOTAL (rounded) e					885			$45,200
Assumptions:
a We estimate that an average of 74 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $70.56 for managerial, $52.37 for technical, and $28.34 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2022 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.
c We assume that 10 percent of the facilities will have exceedance reports.
d Assume that 10 percent of facilities will not have a qualified operator available for more than two weeks at least once a year, and that two corrective action summaries will be required.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.