Burden Calculation Tables

1773t13.xlsx

NESHAP for Hazardous Waste Combustors (40 CFR Part 63, Subpart EEE) (Renewal)

Burden Calculation Tables

OMB: 2060-0743

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Overview

Summary
Table 1
Table 2
Responses
Capital O&M
Respondents


Sheet 1: Summary

ICR Summary Information
Hours per Response 40
Number of Respondents 170
Total Estimated Burden Hours 59,100
Total Estimated Costs $9,690,000
Annualized Capital O&M $2,770,000
Total Annual Responses 1467
Form Number Not Applicable

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost - NESHAP for Hazardous Waste Combustors (40 CFR 63, Subpart EEE) (Renewal)





















Total Total Total Hours and Costs












Manager Technical Clerical Person Hours Labor Costs # of Total Total Labor












$157.61 $123.94 $62.52 Per Per Respondents a Hours Cost b










INFORMATION COLLECTION ACTIVITY
Respondent Respondent











1. Applications



















2. Survey and Studies



















3. Reporting requirements



















A. Familiarization with the rule c
0.0 4.0 0.0 4.0 $495.77 33 133.3 $16,525.60










B. Required Activities



















Operation and maintenance plan (63.1206 (c)(7))




















Request for appoval for establishing set points with extrapolation for PM detectors d 0.0 10.0 1.0 11.0 $1,301.94 1 11 $1,301.94











Recommend alternative OPLs for units with ESP or IWSs e 0.0 10.0 1.0 11.0 $1,301.94 6 63 $7,421.04










Feedstreams Analysis Plan (63.1209(c)(2)) f




















Monitor and record feedrates 0.0 0.5 0.0 0.5 $61.97 1 1 $61.97











Perform waste analysis four time annually (non-commercial



















facilities) 0.0 8.0 0.0 8.0 $991.54 1 8 $991.54











Perform waste analysis 50 times annually (commercial



















facilities) 0.0 100.0 0.0 100.0 $12,394.20 1 100 $12,394.20










Quality control program (63.1209(d) and 63.8(d) g




















Develop and implement a CMS QC program 5.0 64.0 10.0 79.0 $9,345.48 29 2,252 $266,346.27










Conduct of performance evaluation and performance evaluation dates (63.1209(d) and 63.8(e)(4)) h



















Conduct a CMS performance evalutaion 4.0 40.0 4.0 48.0 $5,838.17 34 1,642 $199,665.35










Quality control (QC) requirements (63, Subpart EEE Appendix, Section 1.1) i




















Develop and implement a QC program 8.0 140.0 12.0 160.0 $19,362.92 29 4,560 $551,843.33











Revise program, if necessary 1.0 8.0 1.0 10.0 $1,211.66 6 57 $6,906.45










Quality assurance (QA) requirements (63, Subpart EEE Appendix, Section 1.1) j




















Develop and implement a QA program 8.0 120.0 12.0 140.0 $16,884.08 57 7,980 $962,392.79











Revise or update plan, if necessary 1.0 8.0 1.0 10.0 $1,211.66 6.3 63 $7,597.10










Performance Evaluation (Appendix EEE, Section 5) k




















Conduct ACA, RATA, or interference reponse test as



















applicable 0.0 0.0 0.0 0.0 $0.00 0 0 $0










C. Create Information



















D. Gather Information



















E. Write Report



















Cement kilns with in-line raw mills (63.1220(d)) l




















Prepare and submit notification of compliance using the



















emission averaging requirements for cement kilns with in-line



















raw mills 1.0 3.0 1.0 5.0 $591.95 1 5 $591.95










Extension of compliance with emission standards (63.1206(b)(4), 63.6(i), 63.1213, and 63.9(c)) m



















Prepare and submit the request for an extension of compliance 2.0 10.0 4.0 30.0 $1,804.70 7 106.7 $12,031.32











Prepare and submit a progress report, as applicable 1.0 5.0 2.0 15.0 $902.35 7 53.3 $6,015.66










Changes in design, operation, or maintenance (63.1206(b)(5)) n




















Prepare and submit a notification of change in design,



















operation, or maintenance 2.0 52.0 8.0 62.0 $7,260.33 29 1,767 $206,919.41










Compliance with alternative MACT standards when not burning Hazardous Waste(63.1206(b)(1)(ii)) n



















Revise, as necessary, the performance test plan,



















Documentation of Compliance, and start-up, shutdown, and



















malfunction plan to reflect changes that will not adversely



















affect compliance with emission standards or operating



















requirements. 1.0 6.0 4.0 11.0 $1,151.33 29 314 $32,812.76










Applicability of particulate matter and opacity standards during particulate matter CEMS correlation tests (63.1206(b)(8)) o



















Prepare and submit a particulate matter CEMS correlation



















test plan 2.0 16.0 2.0 20.0 $2,423.32 12 247 $29,927.95











Request additional time extension for waiving PM and Opacity stnds 0.0 0.1 0.0 0.1 $12.39 0 0 $0










Alternative hydrocarbon monitoring location for short cement kilns burning haz waste at location other than hot end of kiln p



















Prepare and submit a petition for alternative monitoring



















location and emission standards 1.0 18.0 0.5 19.5 $2,419.82 0 0 $0










Startup, shutdown, and malfunction plan (63.1206(c)(2) and 63.6(e)(3)) q




















Submit for review and approval by EPA 1.0 10.0 2.0 13.0 $1,522.06 7 87 $10,197.80











Excessive emissions reporting 3.0 11.0 1.0 15.0 $1,898.69 6 86 $10,822.56










Automatic waste feed cutoff (63.1206(c)(3)) q




















Develop and submit a written report documenting excessive



















exceedances and result of the investigation and corrective



















measures taken 2.0 16.0 0.5 18.5 $2,329.54 6 105 $13,278.38










ESV openings (63.1206(c)(4)) r




















Develop and submit a written report documenting the ESV


















opening and result of the investigation and corrective



















measures taken, and whether ESV event caused non-compliance 2.0 16.0 0.5 18.5 $2,329.54 34 619.8 $78,039.61










Combustion system leaks (63.1206(c)(5)) s




















Prepare and submit a request to use an alternative means of



















control to provide control of combustion system leaks 0.5 10.0 0.5 11.0 $1,349.48 29 314 $38,460.21










Operation and maintenance plan (63.1206 (c)(7)) t




















Notify EPA if alarm limit is exceeded more than 5% of the time in a 6-month block period 5.0 40.0 0.0 45.0 $5,745.71 11 513 $65,501.04










Comprehensive performance test requirements (63.1207(b)(1)) h, u, v




















Submittal of comprehensive performance test no later than 61



















months after the date of commencing the previous



















comprehensive performance test 2.0 40.0 4.0 46.0 $5,522.96 34 1,573 $188,885.16











Submittal of one-time D/F testing for units w/out numerical D/F stnd 0.5 10.0 1.0 11.5 $1,380.74 1 11.5 $1,380.74











Request 60 day extention to complete testing 1.0 1.0 1.0 3.0 $344.06 11 34 $3,922.33











Request additional time for waiving OPLs for pretesting 1.0 1.0 1.0 3.0 $344.06 6 17 $1,961.16










Confirmatory performance test requirements (63.1207(b)(2)) w




















Perform the confirmatory performance test no later than 31



















months after the date of commencing the previous



















comprehensive performance test 2.0 40.0 4.0 46.0 $5,522.96 29 1,352 $162,374.97










Data in lieu of the initial comprehensive performance test (63.1207(c)(2)) x




















Prepare and submit a request that previous emissions test



















data serve as documentation of conformance with emission



















standards 1.0 8.0 2.0 11.0 $1,274.18 6 63 $7,262.80










Notification of performance test and CMS perfomance evaluation and approval of test plan CMS performance evaluation plan (63.1207(e)) k, y



















Prepare and submit a notification of intention to conduct



















a perfomance test 1.0 4.0 1.0 6.0 $715.89 34 205 $24,483.44











Prepare and submit the rescheduled notification of intent to



















conduct a performance test, if test is postponed 1.0 4.0 1.0 6.0 $715.89 3.4 20.5 $2,448.34











Prepare and submit a site-specific comprehensive



















performance test plan 7.0 110.0 12.0 129.0 $15,487.06 34 4,412 $529,657.42











Prepare and submit the site-specific confirmatory performance



















test plan 2.0 30.0 10.0 42.0 $4,658.64 20.5 861.8 $95,595.29










Notification of compliance (63.1207(j), 63.9(h), 63.7(g), 63.10(d)(2) and 63.1210(d)) z



















Prepare and submit a notification of compliance 10.0 104.0 16.0 130.0 $15,466.29 57 7,410 $881,579











Prepare and submit a written request for a time extension, if



















necessary 0.5 0.0 1.0 1.5 $141.32 6 9 $805.52










Waiver of performance tests and request for time extension (63.1207(h) and 63.1207(m)) z



















Prepare and submit a request for a 6 month time extension for



















conducting a performance test if test plan has not been approved 2.0 24.0 2.0 28.0 $3,414.85 6 160 $19,464.66











Notify public of request for time extension 3.0 2.0 1.0 6.0 $783.22 6 34 $4,464.33










Feedstreams Analysis Plan (63.1209(c)(2))




















Submit the plan for review and approval, if requested by the



















EPA 0.0 0.0 0.5 0.5 $31.26 0 0 $0.00










Alternative compliance monitoring requirements for standards other than those monitored with a CEMS (63.1209(g)(1)) aa



















Prepare and submit an application for use of an alternative



















monitoring method 8.0 100.0 10.0 118.0 $14,280.21 6 673 $81,397.20











Prepare and submit an application to waive an operating limit 4.0 24.0 2.0 30.0 $3,730.06 0 0 $0










Use of CEMS in lieu of OPLs; or alternative methods in lieu of CEMS (63.1209(a)(5)) aa



















Prepare and submit an application for use of an alternative



















monitoring method 8.0 100.0 10.0 118.0 $14,280.21 0 0 $0











Prepare and submit an application to waive an operating limit 4.0 24.0 2.0 30.0 $3,730.06 0 0 $0











Prepare and submit request to extrapolate mercury feedrate



















limits bb 0.5 4.0 1.0 5.5 $637.09 6 31 $3,631.40











Prepare and submit request to extrapolate semivolatile metal



















and low volatile metal feedrate limits bb 0.5 4.0 1.0 5.5 $637.09 6 31 $3,631.40











Submit the CMS quality control program for inspection, if



















requested by the EPA cc 0.0 0.0 0.5 0.5 $31.26 6 3 $178.17










Notification of performance evaluation (63.1209(d) and 63.8(e)(2)) g




















Prepare and submit a notification of CMS performance



















evaluation 1.0 4.0 1.0 6.0 $715.89 29 171 $20,402.87










Additional notification requirements for CMS (63.9(g)(2) and (3)) g




















Prepare and submit additional notification requirements for



















source with CMS 1.0 4.0 1.0 6.0 $715.89 29 171 $20,402.87










Submission of site-specific peformance evaluation test plan (63.1209(d) and 63.8(e)(3)) h



















Develop and submit a CMS site-specific performance



















evaluation test plan 10.0 44.0 8.0 62.0 $7,529.63 34 2,120 $257,513.48










Reporting results of CMS performance evaluations (63.10(e)(2)) h




















Prepare and submit a written report of the results of the



















CMS performance evaluation 1.0 36.0 6.0 43.0 $4,994.62 34 1,471 $170,815.97











Prepare and submit written reports of the results of the



















COMS performance evaluation, as applicable dd 1.0 18.0 4.0 23.0 $2,638.63 0 0 $0










Notice of intent to comply 63.1206(b)-(d) ee




















Prepare draft NIC 9.0 45.0 3.0 57.0 $7,183.39 1 57 $7,183.39











Notify public about meeting and draft NIC 1.0 3.0 2.0 6.0 $654.47 1 6 $654.47











Conduct public meeting 4.0 20.0 3.0 27.0 $3,296.81 1 27 $3,296.81











Prepare and submit final NIC 2.0 35.0 3.0 40.0 $4,840.73 1 40 $4,840.73











Prepare progress report 3.0 30.0 3.0 36.0 $4,378.63 1 36 $4,378.63










Initial notification 63.9(b) and 63.5(d) ff




















Prepare and submit and initial notification 2.0 8.0 1.0 11.0 $1,369.26 1 11 $1,369.26











Prepare and submit an application of approval of construction



















as applicable 7.0 32.0 0.5 39.5 $5,100.64 1 39.5 $5,100.64











Prepare and submit an application of approval of reconstruction



















as applicable 7.0 32.0 0.5 39.5 $5,100.64 1 39.5 $5,100.64










Adjustment to time periods or postmark deadlines for submittal and review of required communications 63.9(i) gg



















Prepare and submit a request for an adjustment to a time



















period or postmark deadline 0.3 2.0 0.5 2.8 $318.54 14 39.2 $4,539.25










Request to reduce frequency of excess emissions and continuous monitoring system performance results 63.10(e)(3)(ii) hh



















Prepare and submit a request to reduce the frequency of



















excess emissions and CMS performance reports 0.3 2.0 0.5 2.8 $318.54 6 15.7 $1,815.70










Waiver of recordkeeping and reporting requirements ii




















Prepare and submit a waiver of recordkeeping and reporting 0.3 2.0 0.5 2.8 $318.54 0.6 1.6 $181.57










Startup, shutdown, and malfunction reports 63.10(d)(5)(i) and (ii) jj




















Prepare and submit a periodic startup, shutdown, and



















malfunction report, as applicable 0.3 5.0 1.0 6.3 $721.63 14 89.1 $10,283.20











Prepare and submit an immediate startup, shutdown, and



















malfunction report, as applicable 0.3 5.0 1.0 6.3 $721.63 6 35.6 $4,113.28










Excess emissions and continuous monitoring system performance report and summary report 63.10(e)(3) kk



















Prepare and submit an excess emissions and monitoring



















system performance report and summary report 0.3 4.0 2.0 6.3 $660.20 57 356 $37,631.59










Data compression ll




















Prepare and submit request for approval to use data



















compression techniques to record data on a less frequent



















basis than required by Section 63.1209 0.3 2.0 0.5 2.8 $318.54 14 39.2 $4,539.25










Extension of the compliance date to install pollution prevention or waste minimization controls (63.1213) mm



















Prepare and submit the request for an extension of compliance



















date due to installation of pollution prevention controls 4.0 24.0 2.0 30.0 $3,730.06 6 171 $21,261.35











Prepare and submit the request for an extension of compliance



















date due to waste minimization controls 4.0 24.0 2.0 30.0 $3,730.06 6 171 $21,261.35










Performance Evaluation (Appendix EEE, Section 5) k




















Prepare and submit a written report of the results of the


















performance evaluation 0.3 1.0 0.0 1.3 $163.34 0 0 $0










Use of alternative CEMS spans (63, Subpart EEE Appendix, Section 6.3.5) nn



















Prepare and submit a request to use an



















alternative CEMS span
0.5 25.0 1.0 26.5 $3,239.87 0 0 $0










Alternative risk based chlorine standards oo




















Make request to use risk based chlorine stnds 2.0 40.0 5.0 47.0 $5,585.48 14 670 $79,593.02










Subtotal for Reporting Requirements
171 1807 204 2,203 $263,618
43,763 $5,237,448










4.  Recordkeeping  requirements



















A.  Familiarization with Regulatory Requirements (see 3A)



















B.  Plan activities (see 3B)



















C.  Implement activities (see 3B)



















D.  Develop record system



















E.  Time to enter information




















Document in operating record compliance with the



















emission averaging requirements for cement kilns with in-line



















raw mills l 0.0 0.5 0.5 1.0 $93.23 1 1 $93.23










Compliance with alternative MACT standards when not burning Hazardous Waste(63.1206(b)(1)(ii)) pp



















Document in the operating record compliance with



















applicable CAA requirements in lieu of the requirements



















of Subpart EEE 0.0 4.0 0.0 4.0 $495.77 3 11 $1,412.94











Document design, operation, or maintenance change in operating record



















if it is determined that the change will not adversely affect compliance with



















emission standards or operating requirements n 0.0 1.0 0.0 1.0 $123.94 29 29 $3,532.35










Hazardous waste residence time qq




















Document hazardous waste residence time in operating record 0.0 4.0 0.5 4.5 $527.03 1 4.5 $527.03










Startup, shutdown, and malfunction plan (63.1206(c)(2) and 63.6(e)(3)) q




















Develop or revise a startup, shutdown, and malfunction plan 6.0 82.0 8.0 96.0 $11,609.01 7 643 $77,780.37










Automatic waste feed cutoff (63.1206(c)(3)) rr




















Investigate the cause of any AWFCO, take appropriate



















corrective measures to minimize future AWFCOs, and



















record the findings and corrective measures in the operating



















record 2.0 16.0 0.5 18.5 $2,329.54 114 2,109 $265,567.62











Test the AWFCO system and associated alarms weekely and



















document and record AWFCO operability test procedures and



















result in the operating record 0.0 1.5 0.0 1.5 $185.91 29 43 $5,298.52











Document in the operating record that weekly inspections will



















unduly restrict or upset operations 0.0 0.5 0.0 0.5 $61.97 29 14 $1,766.17











Test the AWFCO system monthly, and record results in



















operating record 0.0 1.5 0.0 1.5 $185.91 29 43 $5,298.52











Document in the operating record the operating and maintenance



















plan ramp down procedures, as applicable 0.5 6.0 1.0 7.5 $884.97 114 855 $100,886.75










ESV openings (63.1206(c)(4)) r




















Develop an ESV operating plan and keep it in the operating



















record 2.0 20.0 1.0 23.0 $2,856.57 11.2 256.8 $31,898.33











Investigate the cause of the ESV opening, take appropriate



















corrective measures to minimize such future ESV openings,



















record the findings and corrective measures in the operating



















record, and determine if ESV caused non-compliance 2.0 16.0 0.5 18.5 $2,329.54 34 619.8 $78,039.61










Combustion system leaks (63.1206(c)(5)) s




















Specify in the comprehensive test workplan and the notification



















of compliance the methods used to control combustion system leaks 0.0 0.3 0.0 0.3 $30.99 29 7.1 $883.09










Operation and maintenance plan (63.1206 (c)(7)) ss, t




















Prepare an operation and maintenance plan and



















put in the operating record 5.0 295.0 10.0 310.0 $37,976.09 7 2,077 $254,439.77











Document alarm limit exceedences and corrective action taken. 5.0 40.0 0.0 45.0 $5,745.71 11 513 $65,501.04










Feedstreams Analysis Plan (63.1209(c)(2)) f




















Develop and implement a feedstream analysis plan and



















put plan in the operating record 1.0 5.0 1.0 7.0 $839.83 1 7 $839.83










Dioxins and furans (63.1209(k)) tt




















Document in the operating record procedures



















used to ensure carbon bed lifetime is being



















sufficiently monitored and controlled 0.0 0.3 0.0 0.3 $30.99 0 0 $0











Document in the operating record that replacement carbon



















will provide the same level of control as original carbon



















used during the performance test 0.0 0.3 0.0 0.3 $30.99 0 0 $0











Document in the operating record that replacement inhibitor



















will provide the same level of control as the original inhibitor



















used during the performance test 0.0 0.3 0.0 0.3 $30.99 0 0 $0










Total chlorine (hydrochloride and chlorine gas) (63.1209(o)) tt




















Document in the operating record that replacement sorbent



















will provide the same level of control as the original sorbent



















used during the performance test 0.0 0.3 0.0 0.3 $30.99 0 0 $0










Operating under different modes of operation (63.1207(g) and 63.1209(r)) g, uu




















Document the mode of operation in the operating record, if a



















source has tested under two or more operating modes 0.0 0.3 0.0 0.3 $30.99 29 7.1 $883.09











Keep the CMS quality control program on record for the life



















of the affected source or until the affected source is no



















longer subject to the provisions of 40 CFR Part 63 0.0 0.0 0.5 0.5 $31.26 29 14 $890.87










General recordkeeping requirements 63.10(b) vv




















Retain files of all information (including all reports and)



















notifications) for atleast 5 years 0.0 0.0 40.0 40.0 $2,500.68 57 2,280 $142,539










Additional recordkeeping requirements for source with CMS (63.10(c)) vv




















Maintain additional records for continuous monitoring



















systems 0.0 0.0 20.0 20.0 $1,250.34 57 1,140 $71,269










Documentation of Compliance 63.1211(d) ww




















Develop a Documentation of Compliance and include it in the



















operating record 1.0 10.0 2.0 13.0 $1,522.06 57 741 $86,757.36










Quality control (QC) requirements (63, Subpart EEE Appendix, Section 1.1) j




















Record program in operating record 0.0 20.0 0.0 20.0 $2,478.84 57 1,140 $141,294










Quality assurance (QA) requirements (63, Subpart EEE Appendix, Section 1.1) j




















Record plan in the operating record 0.0 10.0 0.0 10.0 $1,239.42 57 570 $70,647










Calibration drift (CD) and zero drift (ZD) assessment and daily system audit (63, Subpart EEE Appendix, Section 4) j



















Check, record, and quantify the ZD and the CD



















at least once daily (330 times per year) 0.0 0.0 0.0 0.0 $0.00 57 0 $0











Retain all CEMS measurements in the



















operating record for at least 5 years 0.0 1.0 0.0 1.0 $123.94 57 57 $7,064.69










F.  Train personnel



















Operator training and certification (63.1206(c)(6)) yy




















Develop an operator training and certification program 6.8 136.0 13.6 156.4 $18,778.06 6 891.5 $107,034.93











Implement an operator training and certification program 0.6 12.0 1.2 13.8 $1,656.89 57 787 $94,442.58











Keep a record of the plan and records of certification and training activities 0.4 8.0 0.8 9.2 $1,104.59 57 524 $62,961.72










G.  Audits



















Subtotal for Recordkeeping Requirements
32 692 101 825 $97,117
15,385 $1,679,549










TOTAL LABOR BURDEN AND COSTS (ROUNDED) zz
203 2498 305 3030 $361,000
59,100 $6,920,000










TOTAL CAPITAL AND O&M COST (ROUNDED) zz







$2,770,000










GRAND TOTAL (ROUNDED) zz







$9,690,000










a The total number of respondents estimated over the next three years is based on approximately 168 existing units at 94 facilities that are subject to the standard, with three new units (one per year) over the same period, resulting in an average of 170 existing respondents and 1 new respondent per year. The overall average number of respondents submitting reports in each year is calculated as one-third of the total respondents and is 57 respondents per year.










b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour 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 Assumes respondents take 4 hours to refamiliarize themselves with rule requirements each year.


















d Assumes 1 respondent per year will request appoval for establishing set points with extrapolation for PM detectors.


















e It is estimated that of the sources reporting annually with ESPs or IWSs, 10% will request to use operating parameter limits instead of continuous particulate detectors.


















f Provides for one-time requirement for development and implementation of feedstream analysis plans for new respondents.










g As part of the comprehensive performance test, HWCs will submit a CMS quality control program, notification of performance evaluation and additional notification requirements; we estimate that 50% of sources have submitted a CMS quality control program at this time.










h HWCs are also required to submit a performance evaluation test plan, and conduct a CMS performance test. We estimate 60% of sources would submit test plans and conduct performance testing along with their comprehensive performance testing.










i Assumes that respondents will develop and implement a QC program for 50% of units, and 10% will submit a revised QC program.


















j All sources must meet the QA requirements for CEMS. Assumes all sources will develop a QA program and 11% will submit a revised QA program.


















k Burden for performance evaluations is included in the the notification of performance test and CMS performance evaluations.


















l We estimate that 1 cement kiln with an in-line kiln raw mill will comply with the emission averaging requirements for kilns of this type. Thus, they will conduct a performance test when the raw mill is on-line and when the mill is off-line, and include the averaging procedures in their Notification of Compliance and operating record.










m Assumes 20% of all facilities operating an HWC will apply for an extension each year.


















n It is estimated that 50% of the sources reporting annually will be making design, operation, and maintenance changes to comply with the MACT rule and document change in operating record.










o It is anticipated that 65% of sources (among all HWC) will conduct PM CEMS correlation testing over the 3-year period of this ICR and request a waiver of PM and opacity standards during the testing. It is estimated that none of these sources will request an extension of the 96 hours allowed for the waiver.










p Assumes no respondents will petition for an alternative monitoring location or emission standards.


















q Assumes 1 new respondent and 10% of existing respondents reporting annually will develop or revise the SSM plan and resubmit the plan for approval, and 10% of respondents would be required to submit excess emissions reports.










r It is estimated that 50% of hazardous waste incinerators reporting annually have ESVs, and will develop an ESV operating plan. On average, each unit will have 3 ESV openings per year.










s It is estimated that respondents will request approval for 50% of all sources for use of an alternative means to provide control of combustion system leaks (control through a positively sealed combustion chamber).










t Assumes all units with fabric filters (about 60% of sources) will have to purchase, install, and operate bag leak detection systems over the three year period of this ICR.


















u Assumes 1 new respondent will submit one-time D/F testing for units without a numerical D/F standard.


















v Assumes 20% of sources will request an extension of the comprehensive performance test and 10% of sources will request additional time for waiving OPLs for pretesting.


















w It is assumed that 60% of units with PCDD/PCDF limits would be required to test over the three-year period of this ICR.


















x It is estimated that 10% of all sources reporting annually will submit a request to use previous emissions test data to serve as documentation of compliance with emission standards.


















y Assumes 60% of respondents must conduct a comprehensive performance test every 3 years and 60% of respondents must conduct a confirmatory performance every 5 years. It is estimated that 10% of these sources would reschedule the test.










z All facilities will submit a Notification of Compliance. It is estimated that 10% of facilities conducting the comprehensive performance test will apply for a waiver or time extension.


















aa It is estimated that 10% of all facilities will apply for and receive approval to use alternative monitoring requirements to document compliance with the emission standards of Subpart EEE other than CO or HC which are monitored with a CEMS. It is estimated that no facilities will make a request to use alternative operating parameters or methods to CEMS or CEMS in lieu of operating parameters.










bb It is estimated that no existing sources will chose to use a CEMS for compliance monitoring and that 10% of sources will make a request to set feedrate limits with extrapolation.


















cc It is estimated that EPA will request additional relevant information for the site-specific CMS performance test plan from 10% of the sources performing the test.


















dd This requirement only applies to cement kilns without bag leak systems and PM detectors. It is estimated that all existing sources have these systems in place.


















ee Assumes one respondent will prepare a draft NIC, notify the public about a NIC meeting, conduct the NIC meeting, prepare a final NIC with meeting comments, submit the NIC to EPA, and complete the progress report for one new HWC.










ff Assumes one respondent will submit initial notifications for a new HWC.


















gg We estimate that 25% of all facilities will submit a request for an adjustment to a time period or postmark deadline.


















hh It is estimated that 10% of facilities will submit a request to reduce frequency of excess emissions and continuous system performance reports from a quarterly (or more frequent basis).










ii It is estimated that 1% of all facilities reporting annually will submit a waiver of recordkeeping or reporting requirements.


















jj It is anticipated that 25% of facilities will take actions during a startup, shutdown, or malfunction that are consistent with the procedures specified in the facility's startup, shutdown, or malfunction plan. These facilities are required to submit a periodic startup, shutdown, and malfunction report. Another 10% of facilities will take actions that are not consistent with procedures specified in their plans. These facilities acquired to submit an immediate startup, shutdown, and malfunction report.










kk It is anticipated that all facilities will submit an excess emissions and continuous monitoring system performance report and summary report.


















ll It is estimated that 25% of facilities will submit a request for approval to use data compression techniques.


















mm It is estimated that 10% of sources will submit a one-time request for a compliance extension due to the installation of controls, and that another 10% will submit a one-time request for a compliance extension for waste minimization purposes.










nn It is estimated that no source will submit requests to use an alternative CEMS span.


















oo It is estimated that 25% of facilities will request to comply with the alternative risk based chlorine standards.


















pp Assumes 5% of all respondents will document in the operating record compliance with alternative applicable Clean Air Act requirements and standards.


















qq Assumes one respondent will document the hazardous waste residence time in the operating record for a new HWC.


















rr It is estimated that all sources (units) will have 2 AWFCO per year. We assume 50% of units will conduct weekly AWFCO system inspections, while 50% will conduct monthly system testing;










ss Assumes 10% of existing respondents are updating an O&M plan and 1 new respondent is developing the plan. Further assumes 60% of sources will document alarm limit exceedences and corrective action taken.










tt It is estimated that no facilities will make a request to use alternative operating parameters or methods to CEMS.


















uu It is estimated that 50% of all facilities will perform the comprehensive performance test under two or more operating modes. These facilities will be required to document what operating mode they are in during subsequent on-going day to day operations.










vv It is estimated that it will take 40 hours each year for each of the HWC facilities to maintain copies of all required information (information must be retained for five years). All sources will need to maintain copies of all required information for continuous monitoring systems.










ww It is anticipated that all facilities will develop a Documentation of Compliance to be included in their operating records


















yy Assumes 10% of respondents will update or develop the operator training and certification program each year. Assumes all respondents are conducting annual training.


















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



















Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Hazardous Waste Combustors (40 CFR Part 63, Subpart EEE) (Renewal)












Hours and Costs Per Respondent or Activity
Total Hours and Costs










Manager Technical Clerical Total Person Hrs Per
Total Labor # Of Total Labor Total


$70.56 $52.37 $28.34 Respondent
Cost Per Respondent Respondents a Hours Costs b
INFORMATION COLLECTION ACTIVITY












Operation and Maintenance Plan c










Review request to use alternative OPLs for ESP and ISWs 0.3 8.0 0.0 8.3
$436.58 5.7 47.0 $2,488.53

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $254.93
Analysis of feedstream d










Request feedstream analysis plan 0.8 10.0 0.3 11.0
$583.68 0.0 0.0 $0.00
Extension of the compliance date to install pollution prevention waste minimization controls e









Review requests for an extension of compliance date 1.0 4.0 0.3 5.3
$287.12 11.4 59.9 $3,284.52
Extension of compliance with emission standards f










Review requests for extension of the compliance date 0.5 4.0 0.0 4.5
$244.75 6.7 30.0 $1,631.68

Review progress reports, if required by EPA 0.5 1.0 0.0 1.5
$87.65 6.7 10.0 $584.32

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 6.7 3.3 $198.16
Changes in design, operation, or maintenance g










Review notifications of changes in design, operation, or









maintenance 3.0 15.0 0.0 18.0
$997.20 28.5 513.0 $28,420

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 28.5 14.3 $733.13
Applicability of particulate matter and opacity standards during PM CEMS correlation tests h









Review of PM CEMS correlation test plans 0.3 10.0 0.0 10.3
$541.32 12.4 126.6 $6,685.30

Notify applicants of EPA' determination 0.3 0.0 0.3 0.5
$24.72 12.4 6.2 $317.69
Alternative particulate matter standard for liquid fuel boilers with low feedrates of metals i









Review petitions for alternative particulate matter standard









for liquid boilers with low feedrates of metals 0.5 15.0 0.0 15.5
$820.80 2.1 32.6 $1,723.68

Notify applicants of EPA' determination 0.3 0.0 0.3 0.5
$24.72 2.1 1.1 $51.92
Startup, shutdown, and malfunction plan j










Review startup, shutdown, and malfunction plans, notify









applicant of results of review 0.5 5.0 0.0 5.5
$297.12 6.7 36.9 $1,997.40
Automatic waste feed cutoff k










Review excessive exceedance reports 0.3 5.0 0.1 5.4
$282.31 5.7 30.5 $1,609.19

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63
ESV openings l










Review ESV openings report 0.3 5.0 0.1 5.4
$282.31 33.5 179.2 $9,457.51

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 33.5 16.8 $861.75
Combustion system leaks m










Review requests for approval of alternative means of









combustion system leak control 0.5 2.0 0.0 2.5
$140.02 28.5 71.3 $3,990.46

Notify applicants of EPA' determination 0.3 0.0 0.3 0.5
$24.72 28.5 14.3 $733.13
Data in lieu of the initial comprehensive performance test n










Review requests to base initial compliance data in lieu of a









comprehensice performance test 2.0 20.0 0.0 22.0
$1,188.48 5.7 125.4 $6,774.34

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63
Notifcation of performance test and CMS performance evaluation and approval of test plan and CMS performance evaluation plan o









Review notifications of intention to conduct a performance









test 0.3 0.3 0.0 0.5
$30.73 34.2 17.1 $1,051.03

Review notifications of delay in conducting a performance









test 0.3 0.3 0.0 0.5
$30.73 3.4 1.7 $105.10

Review site-specific comprehensive performance test plans 5.0 50.0 0.0 55.0
$2,971.20 34.2 1881.0 $101,615

Review site-specific confirmatory performance test plans 2.0 10.0 0.0 12.0
$664.80 20.5 246.2 $13,641.70

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 34.2 17.1 $1,529.56
Notification of compliance p










Review notifications of compliance 3.0 40.0 0.0 43.0
$2,306.40 57.0 2451.0 $131,465

Review requests for a time extension for Notification of









Compliance 0.3 4.0 0.0 4.3
$227.11 5.7 24.2 $1,294.54

Notify applicants of the EPA' s determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $140.93
Waiver of performance tests and request for time extension p










Review requests to waive a performance test or extension for









conducting a performance test (other than the initial comprehensive









performance test) 4.0 16.0 0.0 20.0
$1,120.13 5.7 114.0 $6,384.73

Notify applicants of EPA' s determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $140.93
Alternative compliance, monitoring requirements for standards other than those monitored with a CEMS q









Review requests for approval of alternative monitoring









methods, except for standards that must be monitored with a









CEMS 0.5 10.0 0.0 10.5
$558.96 5.7 59.9 $3,186.07

Review requests for approval of a waiver of an operating









parameter limit 1.0 10.0 0.0 11.0
$594.24 0.0 0.0 $0

Notify applicants of the EPA's determination for approval of









alternative monitoring requirements 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63

Notify applicants of the EPA's determination for approval of a









waiver of an operating parameter limit 0.3 0.0 0.3 0.5
$24.72 0.0 0.0 $0
Dioxins and furans q










Review requests for approval to substitute a different brand









or type of carbon 0.5 2.0 0.0 2.5
$140.02 0.0 0.0 $0

Review requests for approval to substitute a different brand









or type of inhibitor 0.5 2.0 0.0 2.5
$140.02 0.0 0.0 $0

Notify applicants of the EPA's determination for approval to









substitute a different brand or type of carbon 0.5 0.3 0.0 0.8
$48.37 0.0 0.0 $0

Notify applicants of the EPA's determination for approval to









substitute a different brand or type of inhibitor 0.5 0.3 0.0 0.8
$48.37 0.0 0.0 $0
Mercury q, r










Review requests for approval to use a CEMS in lieu of









operating parameter limits 0.3 2.0 0.0 2.3
$122.38 0.0 0.0 $0

Review requests to extrapolate mercury feedrate limits 0.3 2.0 0.0 2.3
$122.38 5.7 12.8 $697.54

Notify applicants of the EPA's determination to extrapolate









mercury feedrate limits 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63

Notify applicants of the EPA's determination for approval to









use a CEMS 0.3 0.0 0.3 0.5
$24.72 0.0 0.0 $0
Semivolatile and low semivolatile metals q, r










Review requests for approval to use a CEMS in lieu of









operating parameter limtis 0.3 2.0 0.0 2.3
$122.38 0.0 0.0 $0

Review requests to extrapolate semivolatile metal and low









volatile metal feedrate limits 0.3 2.0 0.0 2.3
$122.38 5.7 12.8 $697.54

Notify applicants of the EPA's determination to extrapolate









SVM and LVM feedrates 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63

Notify applicants of the EPA's determination for approval to









use a CEMS 0.3 0.0 0.3 0.5
$24.72 0.0 0.0 $0
Total chlorine (hydrogen chloride and chlorine gas) q










Review requests for approval to substitute a different brand









or type of sorbent 0.3 2.0 0.0 2.3
$122.38 5.7 12.8 $697.54

Review requests for approval to use a CEMS in lieu of









operating parameter limtis 0.3 2.0 0.0 2.3
$122.38 0.0 0.0 $0

Notify applicants of the EPA's determination for approval to









substitute a different brand or type of sorbent 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63

Notify applicants of the EPA's determination for approval to









use a CEMS 0.3 0.0 0.3 0.5
$24.72 0.0 0.0 $0
Quality control program s










Review CMS quality control program 0.3 10.0 0.0 10.3
$541.32 5.7 58.4 $3,085.52

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $380.33
Notification of performance evaluation t










Review notifications of CMS performance evaluation 0.0 0.3 0.1 0.4
$15.93 28.5 10.0 $453.88
Additional notification requirements for sources with continuous monitoring systems t









Review additional notification requirements for source with









CMS 0.3 1.0 0.0 1.3
$70.01 28.5 35.6 $1,995.23
Submission of site-specific performance evaluation test plan u










Review site-specific performance evaluation test plans 1.0 10.0 0.0 11.0
$594.24 34.2 376.2 $20,323.01

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 34.2 17.1 $1,529.56
Reporting results of continuous monitoring system performance evaluations u










Review written reports of the results of the CMS performance









evaluation 0.5 5.0 0.0 5.5
$297.12 34.2 188.1 $10,161.50
Notice of Intent to Comply v










Review draft and final NIC 2.0 30.0 0.0 32.0
$1,712.16 1.0 32.0 $1,732.16

Attend public meeting 0.0 10.0 0.0 10.0
$523.68 1.0 10.0 $523.68
Initial notification w










Review intial notifications 0.3 1.0 0.0 1.3
$70.01 1.0 1.3 $70.01

Review applications of approval of construction 0.3 10.0 0.0 10.3
$541.32 1.0 10.3 $541.32

Review applications of approval of reconstruction, as









applicable 0.3 1.0 0.0 1.3
$70.01 1.0 1.3 $70.01

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 1.0 0.5 $25.72
Adjustment to time periods or postmark deadlines for submittal and review of equiped communications x









Review requests for an adjustment to time periods or









postmark deadlines for submittal and review of required









informaiton 0.5 1.0 0.0 1.5
$87.65 14.3 21.4 $1,248.98

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 14.3 7.1 $366.57
Request to reduce frequency of excess emissions an continuous monitoring system performance results y









Review requests to reduce the frequency of excess









emissions and CMS performance reports 0.5 1.0 0.0 1.5
$87.65 5.7 8.6 $499.59

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $146.63
Waiver of record keeping and reporting requirements z










Review waivers of recordkeeping or reporting 0.5 1.0 0.0 1.5
$87.65 0.6 0.9 $49.96

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 0.6 0.3 $14.66
Startup shutdown and malfunction reports aa










Review startup, shutdown, and malfunction report, as









applicable 0.3 5.0 0.0 5.3
$279.48 14 74.8 $3,982.59

Review immediate startup, shutdown, and malfunction









report, as applicable 0.3 1.0 0.0 1.3
$70.01 6 7.1 $399.05
Excess emissions and continuous monitoring system performance report and summary report bb









Review excess emissions and monitoring system









performance reports and summary reports 0.3 5.0 0.0 5.3
$279.48 57.0 299.3 $15,930.36

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 57.0 28.5 $1,466.27
Data compression cc










Review requests for approval to use date compression









technigues to record data on a less frequent basis 0.5 1.0 0.0 1.5
$87.65 14.3 21.4 $1,248.98

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 14.3 7.1 $366.57
Performance Evaluation dd










Review data collected from CEMS performance evaluation 0.5 5.0 0.0 5.5
$297.12 0.0 0.0 $0

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 0.0 0.0 $0
Use of alternative CEMS spans ee










Review requests for approval to use alternative CEMS spans









and ranges 1.0 4.0 0.0 5.0
$280.03 0.0 0.0 $0

Notify applicants of the EPA's determination 0.3 0.0 0.3 0.5
$24.72 0.0 0.0 $0
Alternative Risk Based Chlorine Standards ff










Review request for use of alternative risk based chlorine standards 3.0 20.0 2.0 25.0
$1,315.71 14.3 356.3 $18,763.15
Compliance with alternative MACT standards gg










Review operating record documenting compliance with all









applicable CAA requirements and standards when not









burning hazardous waste 0.5 2.0 0.0 2.5
$140.02 2.9 7.1 $399.05

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 2.9 1.4 $73.31
Hazardous waste residence time hh










Review determination of hazardous waste residence time 0.3 2.0 0.0 2.3
$122.38 1.0 2.3 $122.38

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 1.0 0.5 $25.72
Operator training and certification ii










Review operator training and certification programs 0.3 15.0 0.0 15.3
$803.16 5.7 86.9 $4,578.01

Notify applicants of EPA's determination 0.3 0.0 0.3 0.5
$24.72 5.7 2.9 $254.93
Additional mailing materials and postage costs (non-labor)








$2,150
TOTAL ANNUAL BURDEN AND COST (ROUNDED) jj







7,870 $428,000
a The total number of respondents estimated over the next three years is based on approximately 168 existing units at 94 facilities that are subject to the standard, with three new units (one per year) over the same period, resulting in an average of 170 existing respondents and 1 new respondent per year. The overall average number of respondents submitting reports in each year is calculated as one-third of the total respondents and is 57 respondents per year.
b Labor cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 for Managerial (GS-13, Step 5, $40.50 x 1.6), $48.08 for Technical (GS-12, Step 1, $30.05 x 1.6) and $26.02 Clerical (GS-6, Step 3, $16.26 x 1.6). These rates are from the Office of Personnel Management (OPM), 2017 General Schedule, which excludes locality rates of pay.
c It is estimated that of the sources reporting annually with ESPs or IWSs, 90% will request to use operating parameter limits instead of continuous particulate detectors.








d Assumes all HWCs have already developed and implemented feedstream analysis plans under current RCRA requirements (referred to as the waste analysis plan). There is no incremental burden for this requirement.
e It is estimated that 10% of sources will submit a one-time request for a compliance extension due to the installation of controls, and that another 10% will submit a one-time request for a compliance extension for waste minimization purposes.
f Assumes 20% of all facilities operating an HWC will apply for an extension each year.








g It is estimated that 50% of the sources reporting annually will be making design, operation, and maintenance changes to comply with the MACT rule.








h It is anticipated that 39 sources (among all HWC) will conduct PM CEMS correlation testing over the 3-year period of this ICR and request a waiver of PM and opacity standards during the testing.








i Assumes 10% of respondents will submit a petition for an alternative particulate matter standard for liquid fuel boilers with low feedrates.








j Assumes 1 new respondent and 10% of existing respondents reporting annually will develop or revise the SSM plan and resubmit the plan for approval.








k Assumes 10% of respondents will submit AWFCO excessive exceedance reports.








l It is estimated that 50% of hazardous waste incinerators reporting annually have ESVs, and will develop an ESV operating plan. On average, each unit will have 3 ESV openings per year.








m It is estimated that respondents will request approval for 50% of all sources for use of an alternative means to provide control of combustion system leaks (control through a positively sealed combustion chamber).
n It is estimated that 10% of all sources reporting annually will submit a request to use previous emissions test data to serve as documentation of compliance with emission standards.








o Assumes 60% of respondents must conduct a comprehensive performance test every 3 years and 60% of respondents must conduct a confirmatory performance every 5 years.








p All facilities will submit a Notification of Compliance. It is estimated that 10% of facilities conducting the comprehensive performance test will apply for a waiver or time extension.








q It is estimated that 10% of all facilities will apply for and receive approval to use alternative monitoring requirements to document compliance with the emission standards of Subpart EEE other than CO or HC which are monitored with a CEMS. It is estimated that no facilities will make a request to use alternative operating parameters or methods to CEMS or CEMS in lieu of operating parameters.
r It is estimated that no existing sources will chose to use a CEMS for compliance monitoring and that 10% of sources will make a request to set feedrate limits with extrapolation.








s It is estimated that EPA will request additional relevant information for the site-specific CMS performance test plan from 10% of the sources performing the test.








t As part of the comprehensive performance test, HWCs will submit a CMS quality control program, notification of performance evaluation and additional notification requirements; we estimate that 50% of sources have submitted a CMS quality control program at this time.
u HWCs are also required to submit performance evaluation test plan, and conduct a CMS performance test. We estimate 60% of sources would submit test plans and conduct performance testing along with their comprehensive performance testing.
v Assumes one respondent will prepare a draft NIC, notify the public about a NIC meeting, conduct the NIC meeting, prepare a final NIC with meeting comments, submit the NIC to EPA, and complete the progress report for one new HWC.
w Assumes one respondent will submit initial notifications for a new HWC.








x We estimate that 25% of all facilities will submit a request for an adjustment to a time period or postmark deadline.








y It is estimated that 10% of facilities will submit a request to reduce frequency of excess emissions and continuous system performance reports from a quarterly (or more frequent basis).








z It is estimated that 1% of all facilities reporting annually will submit a waiver of recordkeeping or reporting requirements.








aa It is anticipated that 25% of facilities will take actions during a startup, shutdown, or malfunction that are consistent with the procedures specified in the facility's startup, shutdown, or malfunction plan. These facilities are required to submit a periodic startup, shutdown, and malfunction report. Another 10% of facilities will take actions that are not consistent with procedures specified in their plans. These facilities acquired to submit an immediate startup, shutdown, and malfunction report.
bb It is anticipated that all facilities will submit an excess emissions and continuous monitoring system performance report and summary report.








cc It is estimated that 25% of facilities will submit a request for approval to use data compression techniques.








dd Burden for performance evaluations is included in the the notification of performance test and CMS performance evaluations.








ee It is estimated that no source will submit requests to use an alternative CEMS span.








ff It is estimated that 25% of facilities will request to comply with the alternative risk based chlorine standards.








gg Assumes 5% of all respondents will document in the operating record compliance with alternative applicable Clean Air Act requirements and standards.








hh Assumes one respondent will document the hazardous waste residence time in the operating record for a new HWC.








ii Assumes 10% of respondents will update or develop the operator training and certification program each year.








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








kk It is estimated that 10% of sources will submit a one-time request for a compliance extension due to the installation of controls, and that another 10% will submit a one-time request for a compliance extension for waste minimization purposes.









Sheet 4: Responses

Total Annual Responses


(A)
Information Collection Activity
(B)
No. of Responses Submitted Per Year
(C)
Number of Existing Respondents That Keep Records But Do Not Submit Responses
(D)
Total Annual Responses
(D) = (B+C)



Cement kilns with in-line raw mills
1 0 1


Extension of compliance with emission standards and compliance report 13 0 13


Changes in design, operation, or maintenance
29 0 29


Compliance with alternative MACT standards when not burning Hazardous Waste 29 3 31


Applicability of particulate matter and opacity standards during particulate matter CEMS correlation tests 12 0 12


Alternative hydrocarbon monitoring location for short cement kilns burning haz waste at location other than hot end of kiln 0 0 0


Startup, shutdown, and malfunction plan and excessive emissions report
12 0 12


Automatic waste feed cutoff exceedances report, testing results, and documentation 6 86 91


Automatic waste feed cutoff operating and maintenance plan ramp down procedures 0 114 114


ESV openings - reports and operating plan
34 11 45


Combustion system leaks - request for altermative means of control
29 29 57


Operator training and certification program
0 57 57


Operation and maintenance plan
11 18 30


Comprehensive performance test requirements, D/F testing, and extensions
52 0 52


Confirmatory performance test requirements
29 0 29


Data in lieu of the initial comprehensive performance test
6 0 6


Notifications of performance test and CMS perfomance evaluation and approval of test plan CMS performance evaluation plan 92 0 92


Notification of compliance and time extension 63 0 63


Waiver of performance tests and request for time extension 11 0 11


Feedstreams Analysis Plan
0 0 0


Alternative compliance monitoring requirements for standards other than those monitored with a CEMS 6 0 6


Use of CEMS in lieu of OPLs; or alternative methods in lieu of CEMS 0 0 0


Mercury, request to extrapolate feedrate lmits and semivolatile metal and low volatile metal feedrate limits 11 0 11


Dioxins and furans, operating records
0 0 0


Total chlorine, CMS quality control plan and operating records
6 0 6


Operating under different modes of operation 0 29 29


Notification of performance evaluation
29 0 29


Additional notification requirements for CMS
29 0 29


Submission of site-specific peformance evaluation test plan 34 0 34


Reporting results of CMS and COMS performance evaluations
34 0 34


Notices of intent to comply
5 0 5


Initial notification, applications of construction and reconstruction
3 0 3


Adjustment to time periods or postmark deadlines for submittal and review of required communications 14 0 14


Request to reduce frequency of excess emissions and continuous monitoring system performance results 6 0 6


Periodic and immediate startup, shutdown, and malfunction reports
20 0 20


Excess emissions and continuous monitoring system performance report and summary report 57 0 57


Request for approval for data compression
14 0 14


Extension of the compliance date 11 0 11


Performance Evaluation Report
0 0 0


Request to use alternative CEMS spans (63, Subpart EEE Appendix, Section 6.3.5) 0 0 0


Request for alternative risk based chlorine standards
14 0 14


General recordkeeping requirements 63.10(b)
0 57 57


Additional recordkeeping requirements for source with CMS (63.10(c))
0 57 57


Waiver of recordkeeping and reporting requirements
1 0 0


Documentation of Compliance
0 57 57


Quality control (QC) requirements 0 57 57


Quality assurance (QA) requirements 0 57 57


Calibration drift (CD) and zero drift (ZD) assessment and daily system audit 0 114 114





Total 1,467














40 hrs/response


Sheet 5: Capital O&M



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








(A) (B) (C) (D) (E) (F) (G)
Continuous Monitoring Device Capital/Startup Cost for One Respondent Number of New Respondents Total Capital/Startup Cost, (B X C) Annual O&M Costs for One Respondent Number of Respondents with O&M Total O&M,
(E X F)

Bag leak/PM Detectors $6,000 1 $6,000 $500 11.4 $5,700
Correlation testing $18,000 1 $18,000 $2,000 12.35 $24,700
CEMS (CO or THC and O2) a $137,547 1 $137,547 $26,729 1 $26,729
COMs/Opacity Monitoring a $51,949 1 $51,949 $14,725 0 $0
PM CEMS a $158,000 1 $158,000 $34,165 1 $34,165
CPMS $43,500 1 $43,500 $9,700 1 $9,700
Comprehensive performance test $0 0 $0 $60,000 34 $2,052,000
One-time D/F testing for units w/o D/F standard $0 0 $0 $5,000 1 $5,000
Confirmatory performance test $0 0 $0 $6,000 29 $176,400
Mailing Costs for Notifications and Reports
Notifications, requests for approval, and reports $0 0 $0 $8 497 $3,979
Additional notifications $0 0 $0 $1 100 $100
Operator and Training Program
Develop operator training and certification program $0 0 $0 $50 6 $285
Public Notification Costs
Public Notification of Intent to Comply $250 1 $250 $520 1 $520
Recordkeeping Costs
Recordkeeping $200 171 $11,401 $0 0 $0
Total (Rounded) b

$427,000

$2,340,000








a This O&M cost reflects 1st year O&M cost for new sources only. We have assumed no new sources will incur O&M costs for COMS.






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







Sheet 6: Respondents

Number of Respondents (Total for 3-Year Period)

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

(A) (B) (C) (D) (E)
Year Number of New Respondents 1 Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports Number of Existing Respondents That Are Also New Respondents Number of Respondents (E=A+B+C-D)
1 1 168 0 0 169
2 1 169 0 0 170
3 1 170 0 0 171
Average Total Respondents 1 169 0 0 170
Avg. Respondents with Reporting & Recordkeeping each year2 1 56 0 0 57






1 New respondents include sources with constructed, reconstructed and modified affected facilities.




2 The average number of respondents conducting reporting and recordkeeping activities in each year is calculated as 1/3 of the total respondent universe. Figures may not add exactly due to rounding.




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