STANDARD
FORM
83
SUPPORTING
STATEMENT
FOR
ICR
NO.
2164.01
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
EMISSION
GUIDELINES
FOR
EXISTING
OTHER
SOLID
WASTE
INCINERATION
(
OSWI)
UNITS
(
40
CFR
PART
60,
SUBPART
FFFF)

U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
NC
27711
September
2004
1
PART
A
OF
THE
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83
Other
Solid
Waste
Incineration
Units
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
requirements
for
Emission
Guidelines
for
Existing
Other
Solid
Waste
Incineration
(
OSWI)
Units
(
40
CFR
Part
60,
Subpart
FFFF)."

1(
b)
Short
Characterization/
Abstract.

This
supporting
statement
addresses
information
collection
activities
imposed
by
the
Emission
Guidelines
and
Compliance
Times
for
Other
Solid
Waste
Incineration
(
OSWI)

Units
 
40
CFR
Part
60
Subpart
FFFF.
The
emission
guidelines
address
existing
OSWI
units
that
commenced
construction
before
proposal
of
the
emission
guidelines.

The
emission
guidelines
do
not
apply
directly
to
existing
OSWI
unit
owners
and
operators.
The
emission
guidelines
can
be
thought
of
as
"
model
regulations"
that
States
use
in
developing
State
plans
to
implement
the
emission
guidelines.

If
a
State
does
not
develop,
adopt,
and
submit
an
approvable
State
plan,
the
Environmental
Protection
Agency
(
EPA)
must
develop
a
Federal
plan
to
implement
the
emission
guidelines.

Whether
an
OSWI
unit
is
ultimately
regulated
under
a
State
plan
or
Federal
plan,
the
full
respondent
burden
for
the
first
3
years
after
promulgation
of
the
emission
guidelines
is
included
in
this
ICR.
The
OSWI
units
to
be
regulated
include
two
subcategories:
very
small
municipal
waste
combustion
(
VSMWC)
units
and
institutional
waste
incineration
(
IWI)
units.

The
use
of
the
term
"
Designated
Administrator"

throughout
this
document
refers
to
the
person
or
office
designated
by
each
State
plan
to
administer
the
implementation
of
the
plan,
or
to
the
U.
S.
EPA
Administrator
in
the
event
that
a
State's
plan
is
not
approvable
and
a
2
Federal
plan
must
be
developed.
The
term
"
Administrator"

alone
refers
to
the
U.
S.
EPA
Administrator.

This
ICR
presents
the
burden
to
respondents
and
the
Designated
Administrator
(
State
or
Federal
Government).

Respondents
are
owners
or
operators
of
existing
OSWI
units.

This
ICR
includes
the
burden
for
activities
that
will
be
conducted
in
the
first
three
years
following
promulgation
of
the
emission
guidelines.
Attachments
A
and
B
contain
tables
of
the
respondent
and
agency
burden
estimates,

respectively,
for
years
one
through
three.
These
activities
include
reading
the
rule.
Because
the
compliance
date
is
5
years
after
the
emission
guidelines
are
promulgated,
other
activities,
such
as
testing,
monitoring,
recordkeeping,
and
reporting
do
not
begin
until
5
years
after
promulgation.

Therefore,
they
are
not
included
in
the
burden
estimate
for
the
first
3
years.
Although
not
necessary
for
this
ICR,

respondent
and
agency
burden
estimates
for
years
4,
5,
and
6
are
included
in
Attachments
C
and
D
to
provide
perspective
on
the
annual
burden
when
the
rule
is
fully
implemented.

The
requirements
described
below
are
the
minimum
requirements
established
by
the
emission
guidelines.

Although
States
may
choose
to
impose
more
stringent
requirements,
it
is
assumed
for
this
burden
estimate
that
the
State
plans
mirror
the
emission
guidelines.

2.
AUTHORITY/
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
111(
c)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
procedures
by
which:

.
.
.
each
State
shall
submit
to
the
Administrator
a
plan
which
(
A)
establishes
standards
of
performance
for
any
existing
source
for
any
air
pollutant.
.
.
to
which
a
standard
of
performance
would
apply
if
such
existing
source
were
a
new
source,
and
(
B)
provides
for
the
3
implementation
and
enforcement
of
such
standards
of
performance.

The
EPA
is
required,
under
section
129
of
the
CAA,
to
establish
guidelines
for
existing
stationary
sources
that
reflect
the
maximum
achievable
control
technology
(
MACT)
for
achieving
continuous
emission
reductions:

Section
129(
a)(
1)
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
4
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
or
who
is
subject
to
any
requirement
of
this
Act
.
.
.
to
(
A)
establish
and
maintain
such
records,
(
B)
make
such
reports,
(
C)
install,
use,
and
maintain
such
monitoring
equipment
or
methods,
(
D)
sample
such
emissions
(
in
accordance
with
such
methods,
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
E)
provide
such
other
information,
as
he
may
reasonably
require.

Certain
reports
are
necessary
to
enable
a
Designated
Administrator
to
identify
existing
sources
subject
to
the
State
plan
that
implements
the
emission
guidelines
and
to
determine
if
the
guidelines
are
being
achieved.

2(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
the
Designated
Administrators'
enforcement
personnel
to
ensure
that
the
requirements
of
the
State
(
or
Federal)
plan
are
being
implemented
and
are
complied
with
on
a
continuous
basis.

Specifically,
the
information
will
be
used
by
the
Designated
Administrator
to:
(
1)
Identify
existing
sources
subject
to
the
emission
guidelines;
(
2)
ensure
that
subpart
FFFF
is
being
properly
applied;
(
3)
ensure
that
the
emission
limits
are
being
complied
with;
(
4)
ensure,
on
a
continuous
basis,

that
the
operating
limits
established
during
the
initial
performance
test
are
not
exceeded.

In
addition,
records
and
reports
are
necessary
to
enable
the
Designated
Administrator
to
identify
OSWI
units
that
may
not
be
in
compliance
with
the
emission
guidelines.

Based
on
reported
information,
the
Designated
Administrator
can
decide
which
OSWI
units
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
the
OSWI
unit.

The
records
that
OSWI
units
maintain
would
indicate
to
the
5
Designated
Administrator
whether
the
personnel
are
operating
and
maintaining
control
equipment
properly
and
whether
they
have
met
the
qualification
requirements.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication.

This
ICR
contains
reporting
and
recordkeeping
requirements
for
OSWI
units,
whether
regulated
under
a
State
plan
or
Federal
plan.
No
information
is
required
to
be
submitted
in
the
first
3
years
following
promulgation
of
the
emission
guidelines.

Other
activities,
such
as
emissions
testing,
operator
training,
and
monitoring
of
operating
parameters,
do
not
occur
until
5
years
after
promulgation.
This
is
because
the
final
compliance
date
for
existing
facilities
occurs
5
years
after
promulgation
of
the
emission
guidelines
or
3
years
after
EPA
approval
of
a
State
plan.

In
most
cases,
the
enforcement
of
emission
guidelines
has
been
delegated
to
State
air
pollution
control
agencies.

In
such
cases,
the
reports
required
by
the
emission
guidelines
will
be
submitted
to
the
appropriate
State
agency,
and
not
directly
to
the
EPA.
Thus,
there
is
a
minimal
possibility
for
the
submittal
of
duplicate
information
to
State
agencies
and
EPA.
In
those
few
cases
where
State
agencies
have
not
developed
a
State
plan
or
requested
delegation
of
the
Federal
plan,
Federal
enforcement
still
requires
information
from
the
OSWI
facility.
The
facility
owner
or
operator
may
submit
a
copy
of
State
or
local
reports
to
the
Administrator
in
lieu
of
the
report
required
by
the
emission
guidelines
if
it
contains
the
necessary
information,
as
specified
in
the
General
Provisions
of
40
CFR
Part
60.

3(
b)
Public
notice
prior
to
ICR
submission
to
OMB.
6
A
public
notice
of
this
collection
will
be
provided
in
the
notice
of
proposed
rulemaking
for
the
emissions
guidelines.

3(
c)
Consultations.

While
collecting
technical
information
pertaining
to
the
OSWI
category,
EPA
contacted
incinerator
manufacturers
and
associations
as
well
as
State
and
Federal
agencies.
In
addition
to
these
contacts,
EPA
chartered
an
Industrial
Combustion
Coordinated
Rulemaking
advisory
committee
in
1996,
under
the
Federal
Advisory
Committee
Act.
The
committee's
objective
was
to
develop
recommendations
for
regulations
for
several
combustion
source
categories
under
sections
112
and
129
of
the
CAA.
The
EPA
considered
information
received
from
all
of
these
sources
in
the
development
of
the
proposed
emission
guidelines.

The
public
will
also
have
the
opportunity
to
review
and
comment
on
the
proposed
emission
guidelines
and
the
ICR
during
the
specified
comment
period.

3(
d)
Effects
of
Less
Frequent
Data
Collection.

The
emission
guidelines
require
initial
and
annual
performance
tests
for
nine
pollutants
and
opacity,

continuous
emission
monitoring
for
carbon
monoxide
(
CO),

continuous
operating
parameter
monitoring,
annual
operator
training,
and
annual
reporting
(
semiannual
deviation
reports
are
required
if
any
of
the
emission
limits
or
operating
limits
are
exceeded).
The
frequency
of
these
activities
was
chosen
by
EPA
as
the
period
that
will
provide
an
adequate
margin
of
assurance
that
affected
facilities
will
not
operate
for
extended
periods
in
violation
of
the
emission
guidelines.

No
reports
or
data
collection
efforts
are
submitted
in
the
first
3
years
after
promulgation
of
the
emission
guidelines.
The
only
burden
for
owners
and
operators
in
the
first
3
years
is
to
read
and
understand
the
emission
7
guidelines.
The
other
activities
take
place
after
the
compliance
date,
which
will
be
in
the
fifth
year
after
promulgation.

3(
e)
General
Guidelines.

With
the
exception
of
requiring
records
to
be
maintained
for
more
than
3
years,
none
of
the
guidelines
in
5
CFR
1320.5
are
being
exceeded.
This
rule
requires
all
records
to
be
maintained
at
the
source
for
a
period
of
5
years.
In
40
CFR
Part
63,
Subpart
A,
"
General
Provisions
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories,"
owners
or
operators
of
facilities
are
required
to
keep
and
maintain
records
for
a
period
of
5
years.
These
records
must
be
kept
on
file
for
use,
if
needed,
by
the
regulating
authority
to
ensure
that
the
plant
personnel
are
operating
and
maintaining
control
equipment
properly.
Under
section
129
of
the
CAA,
OSWI
facilities
are
subject
to
regulation
under
similar
maximum
achievable
control
technology
(
MACT)­
based
regulations,
therefore,
this
5­
year
record
retention
requirement
was
adopted
for
OSWI
facilities.
Furthermore,
section
129
requires
all
OSWI
units
to
obtain
title
V
operating
permits
under
part
70
or
71
permit
programs.
The
title
V
permit
programs
also
require
records
to
be
retained
for
5
years.
To
minimize
the
burden,
the
emission
guidelines
allow
files
to
be
kept
in
paper
or
electronic
format.
Files
must
be
kept
on
site
for
2
years
but
may
be
kept
off
site
for
the
remaining
3
years.

3(
f)
Confidentiality
and
Sensitive
Questions.

(
i)
Confidentiality.
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
set
forth
in
title
40,

chapter
1,
part
2,
subpart
B
­­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976,

amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,

September
28,
1978;
44
FR
17674,
March
23,
1979).
8
(
ii)
Sensitive
Questions.
This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes.

Respondents
are
owners
or
operators
of
OSWI
units
for
which
construction
commences
on
or
before
the
date
of
proposal
publication
in
the
Federal
Register.
OSWI
units
include
VSMWC
units
that
combust
less
than
35
tons
per
day
of
waste
collected
from
multiple
residences,
businesses,

etc.,
that
are
operated
by
municipalities
(
NAICS
562213,

92411).
OSWI
units
also
include
IWI
units,
as
defined
in
the
regulation,
that
are
located
at
an
institutional
facility
and
combust
waste
generated
at
that
facility.
IWI
units
can
be
located
at
institutions
such
as
schools,

universities,
prisons,
military
bases,
government
facilities,
churches
and
other
institutions
with
NAICS
623,

922,
928,
6111,
6112,
6113,
7121,
8131,
or
8134.

4(
b)
Information
Requested.

(
i)
Data
items.
The
recordkeeping
and
reporting
requirements
of
the
proposed
emission
guidelines
are
described
in
section
4(
b)(
iii)
and
include
the
following:

°
notification
of
final
compliance
(
no
information
is
required
in
the
first
3
years);

°
waste
management
plan;

°
records
of
operator
training
and
qualification;

°
performance
test
reports;

°
records
of
CO
and
operating
parameter
monitoring;

°
annual
compliance
reports;
and
°
semiannual
deviation
reports.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
emission
guidelines
are
provided
under
the
9
first
column
of
Tables
A1
through
A3
in
Attachment
A
and
are
summarized
in
section
(
4)(
b)(
iii).
All
respondent
burden
items
are
included
in
Tables
A1
through
A3,
however,
as
previously
explained,
the
only
respondent
activity
in
the
first
3
years
will
be
reading
the
rules.

(
iii)
Summary
of
emission
guidelines
requirements.

There
are
no
information
collection
activities
in
the
first
3
years
after
promulgation
of
the
proposed
emission
guidelines.

Any
information
collection
activities
included
in
the
emission
guidelines
will
not
occur
until
at
least
5
years
following
promulgation.
Therefore,
the
burden
for
these
items
is
not
included
in
the
ICR,
however,
burden
estimate
tables
have
been
included
as
Attachment
C.
These
items
include:
preparation
of
a
waste
management
plan,

performance
tests,
CO
emissions
monitoring,
operating
parameter
monitoring,
operator
training,
one­
time
and
periodic
reports,
and
the
maintenance
of
records.

Testing
and
Monitoring:
The
emission
guidelines
require
an
initial
performance
test
for
particulate
matter
(
PM),
dioxins/
furans,
opacity,
hydrochloric
acid
(
HCl),

cadmium
(
Cd),
lead
(
Pb),
mercury
(
Hg),
CO,
nitrogen
oxides
(
NOx)
and
sulfur
dioxide
(
SO2).
During
the
initial
performance
test,
the
owner
or
operator
must
establish
limits
for
each
operating
parameter.
Thereafter,
the
owner
or
operator
must
conduct
annual
performance
tests
for
the
nine
pollutants
and
opacity,
and
must
continuously
monitor
CO
and
the
operating
parameters.
The
emission
guidelines
allow
the
owner
or
operator
to
skip
two
annual
performance
tests
for
a
pollutant
if
all
performance
tests
over
the
previous
3
years
show
compliance
with
the
emission
limit.

Operating
Training:
To
ensure
the
proper
operation
of
the
incinerator,
the
emission
guidelines
require
that
each
facility
establish
and
maintain
at
least
one
qualified
OSWI
10
unit
operator
or
supervisor.
The
operator
qualification
process
includes
training,
an
exam,
and
review
of
sitespecific
materials.
The
operator
qualification
requirements
allow
the
flexibility
to
use
State­
approved
training
and
qualification
programs.
To
maintain
qualification
the
operators
or
supervisors
must
attend
an
annual
refresher
course
and
review
site­
specific
materials
annually.

Reporting:
On
or
before
the
compliance
date
specified
by
the
State
or
Federal
plan
implementing
the
emission
guidelines,
the
owner
or
operator
must
submit
a
notification
that
includes
a
statement
of
compliance
with
the
emission
guidelines.
Another
report,
the
waste
management
plan,

identifies
both
the
feasibility
and
the
approach
to
separate
certain
components
of
solid
waste
from
the
waste
stream
to
reduce
the
amount
of
toxic
emissions
from
incinerated
waste.

The
final
compliance
notification
and
waste
management
plan
are
documents
that
need
to
be
prepared
and
submitted
only
once.

Following
the
initial
performance
test,
the
owner
or
operator
must
submit
a
report
that
documents
the
results
of
the
performance
test
for
the
nine
pollutants
and
opacity
and
the
values
for
the
facility's
operating
limits.

An
annual
compliance
report
is
required
that
documents
the
values
for
the
operating
limits,
performance
test
results
and
any
deviations
from
the
emission
limits,

operating
limits
or
other
requirements.

If
there
is
a
deviation
from
the
operating
limits
or
emission
limits,
the
owner
or
operator
must
submit
a
deviation
report
that
provides
details
on
the
deviation.

These
reports
are
submitted
semiannually
if
a
deviation
occurs
during
the
6­
month
period.

Recordkeeping:
As
specified
in
the
emission
guidelines,
owners
or
operators
of
OSWI
units
are
required
to
keep
records
of
certain
parameters
and
information
for
a
11
period
of
5
years.
Owners
or
operators
are
required
to
maintain
records
of
the
initial
performance
test,
annual
performance
tests,
and
any
subsequent
performance
tests.

Owners
or
operators
must
also
maintain
records
of
the
monitoring
data
for
CO
and
the
operating
parameters,
and
records
of
monitoring
device
calibration.

Records
must
be
maintained
for
any
incinerator
malfunctions,
any
deviations
from
the
operating
limits,
and
days
for
which
CO
or
operating
parameter
monitoring
data
were
not
obtained.

Owners
or
operators
must
maintain
the
names
of
persons
who
have
completed
the
review
of
site­
specific
information
and
who
have
met
the
operator
qualification
requirements.

Records
of
all
documentation
for
the
waste
management
plan
must
also
be
maintained.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,

COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
section
6(
c)

and
in
Tables
B1
through
B3
in
Attachment
B.

5(
b)
Collection
Methodology
and
Management.

This
collection
of
information
does
not
require
the
use
of
automated
collection
techniques
because
of
the
relatively
small
number
of
respondents,
if
any,
that
will
be
affected.

See
section
5(
d)
Collection
Schedule.

5(
c)
Small
Entity
Flexibility.

The
EPA
does
not
expect
the
emission
guidelines
to
have
a
significant
small
business
impact.
Therefore,
the
rule
does
not
contain
any
provisions
reserved
exclusively
for
the
benefit
of
small
entities.
However,
the
rule
does
contain
provisions
that
reduce
the
impact
of
the
rule
on
all
regulated
entities,
which
include
small
entities.
Such
provisions
include:
operating
parameter
monitoring
is
12
required
instead
of
continuous
emissions
monitoring
systems(
CEMS)
for
pollutants
other
than
CO;
the
owner
or
operator
is
allowed
to
skip
two
annual
performance
tests
for
a
pollutant
if
all
performance
tests
over
the
previous
3
years
show
compliance;
and
deviation
reports
are
only
required
if
there
is
a
deviation,
otherwise
reporting
is
annual.

5(
d)
Collection
Schedule.

In
the
first
3
years
following
promulgation
of
the
emission
guidelines,
owners
or
operators
would
only
read
the
rule.

In
year
5
the
information
collected
includes
the
following
one­
time­
only
activities:
initial
performance
tests
(
PM,
dioxins/
furans,
opacity,
HCl,
Cd,
Pb,
Hg,
CO,

NOx,
SO2),
initial
operator
training
and
qualification,

waste
management
plan,
and
report
following
initial
performance
test
(
includes
operating
parameter
values).
The
data
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS),
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.

After
year
5,
annual
performance
tests
are
required
for
the
nine
pollutants
listed
above
and
opacity.
Continuous
emission
monitoring
for
CO
and
continuous
parameter
monitoring
is
required.
An
annual
operator
training
refresher
course
and
site­
specific
information
review
is
required.

An
annual
report
is
required
that
includes
compliance
data
on
the
operating
limits,
performance
test
results,
and
identification
of
deviations
from
emission
limits,
operating
limits,
or
other
requirements.

Additionally,
if
the
operating
limits
or
emission
limits
are
exceeded,
the
owner
or
operator
must
submit
a
deviation
report
that
provides
details
on
the
deviation.
If
all
qualified
operators
are
unavailable
for
more
than
2
13
weeks,
a
status
report
must
be
submitted
within
10
days
and
a
corrective
action
summary
must
be
submitted
every
4
weeks
until
compliance
is
achieved.

Information
obtained
from
annual
compliance
reports
will
be
published
and
distributed
through
the
compliance
data
system
(
CDS).
Data
obtained
during
periodic
visits
by
EPA
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden.

The
burden
estimates
are
based
on
a
population
of
372
existing
OSWI
units
in
EPA's
inventory.
Tables
A1
through
A3
in
Attachment
A
present
an
itemized
breakdown
of
the
reporting
and
recordkeeping
requirements
in
the
first
3
years
for
the
respondents
subject
to
the
emission
guidelines.
The
annual
cost
and
labor
burden
estimates
for
reporting
and
recordkeeping
show
that
the
only
requirement
in
the
first
3
years
is
reading
and
understanding
the
emission
guidelines.

6(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
these
requirements
are
presented
in
Tables
A1
through
A3
in
Attachment
A.
The
total
cost
for
each
respondent
activity
includes
labor
costs,
capital/
startup
costs,
and
operating
and
maintenance
(
O&
M)
costs.

(
i)
Estimating
Labor
Costs.
Labor
rates,
on
a
perhour
basis,
are
taken
from
the
Bureau
of
Labor
Statistics
(
BLS)
Web
site
as
posted
in
March
2004.
Attachment
E
contains
the
labor
rate
query
results
from
the
BLS
Web
site.

The
occupational
category
that
is
the
most
similar
to
personnel
at
facilities
operating
OSWI
units
is
assumed
to
be
"
State
and
local
Government."
The
labor
rates
from
the
14
fourth
quarter
of
2003
have
been
multiplied
by
a
factor
of
1.6
so
that
overhead
and
benefits
are
included
in
the
perhour
labor
rates
used
to
estimate
respondent
costs.
The
rates
used
are
$
46.02
for
technical
personnel,
$
67.04
for
management
and
$
34.66
for
clerical
personnel.

(
ii)
Estimating
Capital/
Start­
up
Costs.

There
are
no
capital
costs
associated
with
the
emission
guidelines
in
the
first
3
years.

(
iii)
Total
Operation
and
Maintenance
(
O&
M),
and
Purchase
of
Service
Costs.

There
are
no
operational
or
maintenance
costs
associated
with
the
emission
guidelines
in
the
first
3
years.

6(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
emission
guidelines
development,
no
costs
can
be
attributed
to
the
development
of
the
additional
information
collection
requirements.

Publication
and
distribution
of
the
information
are
part
of
the
AIRS
Facility
subsystem,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
would
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
Designated
Administrator's
overall
compliance
and
enforcement
program
and,
therefore,
could
not
be
attributable
to
the
ICR.

The
only
costs
that
the
Implementing
Agency
would
incur
in
the
first
3
years
are
reading
and
understanding
the
rule,

and
preparing
an
annual
report
that
summarizes
progress
in
implementing
State
plans
and
the
compliance
status
of
the
affected
facilities
in
each
State.
These
items
are
presented
in
Tables
B1
through
B3
in
Attachment
B.
Under
40
CFR
Part
60,
Subpart
B,
the
first
annual
State
progress
reports
are
required
at
the
end
of
the
first
full
calendar
15
year
after
approval
of
the
State
plan
or
promulgation
of
the
Federal
plan.
Section
129
of
the
CAA
allows
1
year
for
States
to
submit
a
State
plan.
The
EPA
would
approve
the
plan
or
promulgate
a
Federal
plan,
if
needed,
in
the
second
year.
Year
three
will
be
the
first
year
after
approval
of
State
plans
or
promulgation
of
the
Federal
plan
and,

therefore,
the
first
year
States
or
EPA
need
to
submit
State
progress
reports.

Labor
rates
for
the
Designated
Administrator's
employees
are
also
based
on
the
estimated
hourly
rates
for
"
State
and
local
Government,"
as
described
above
for
the
respondent
labor
costs,
and
are:
$
46.02
for
technical
personnel;
$
67.04
for
management
personnel;
and
$
34.66
for
clerical
personnel.

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

The
total
number
of
respondents
is
also
referred
to
as
the
respondent
universe.
The
respondent
universe
for
this
ICR
is
based
on
EPA's
OSWI
inventory
database,
which
shows
372
OSWI
units
currently
in
operation.
Each
respondent
owns/
operates
one
OSWI
unit.
Industry
burden
is
calculated
based
on
the
assumption
that
all
existing
OSWI
units
will
remain
in
use
during
years
one
through
three.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
The
Respondent
Tally.
A
breakdown
for
each
of
the
collection,
reporting,
and
recordkeeping
activities
required
by
the
emission
guidelines
is
presented
in
Tables
A1
through
A3
in
Attachment
A.
The
estimate
of
total
annual
hours
requested
from
the
respondents
was
based
on
the
assumptions
outlined
in
section
6(
d)
of
this
ICR.
The
EPA
estimated
the
respondent
burden
for
the
first
3
years
after
adoption
of
the
emission
guidelines
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff
at
the
facility.

Due
to
the
absence
of
capital
or
start­
up
costs
in
the
first
16
3
years,
there
are
no
annualized
capital
costs.
There
are
also
no
operating
and
maintenance
costs
in
the
first
3
years.
The
average
annual
respondent
burden
for
the
3­
year
period
is
5,704
hours
and
$
262,055
of
labor
costs.

(
ii)
The
Designated
Administrator.
The
bottom
line
Designated
Administrator
burden
hours
and
costs,
presented
in
Tables
B1
through
B3
in
Attachment
B,
were
calculated
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff,
and
by
totaling
the
cost
column.
The
average
annual
Agency
burden
over
the
first
3
years
is
383
hours
and
$
17,611
of
labor
costs.
There
are
no
capital,

start­
up
or
operating
and
maintenance
costs
in
the
first
3
years.

(
iii)
Variations
in
the
annual
bottom
line.
The
total
respondent
costs
for
years
1,
2,
and
3
are
$
786,164,
$
0
and
$
0,
respectively.
The
corresponding
total
number
of
respondent
hours
during
this
period
are
17,112
hours,
0
hours,
and
0
hours
(
see
Table
A4
in
Attachment
A).
The
only
activity
during
this
period
is
reading
and
understanding
the
rule.

Most
of
the
burden
of
the
rule,
such
as
initial
and
annual
performance
tests,
operator
training
and
qualification,
monitoring
of
operating
parameter
values,
and
reporting
and
recordkeeping
for
these
activities,
will
not
occur
until
year
5.
Therefore,
the
respondent
burden
for
years
1
through
3
is
minimal.

During
the
first
3
years,
the
Designated
Administrators
will
be
reviewing
the
regulation,
and
preparing
annual
summary
reports.
In
years
1,
2,
and
3,
the
Designated
Administrators
will
expend
920,
0,
and
230
total
hours
in
labor,
respectively.
The
corresponding
costs
for
each
year
are
$
42,267,
$
0,
and
$
10,567
(
see
Table
B4
in
Attachment
B).
17
6(
f)
Reasons
for
change
in
burden.

This
is
the
first
submittal
of
this
burden
estimate;

therefore,
this
section
is
not
applicable.

6(
g)
Burden
Statement.

The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
46
hours
per
response.
Burden
means
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,

maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,

validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
No.
OAR­
2003­
0156,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West
Building,
Room
B102,

1301
Constitution
Ave.,
NW,
Washington,
DC
20460.
The
EPA
18
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.

The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,

and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­

1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
No.
(
OAR­
2003­
0156)
in
any
correspondence.
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
ATTACHMENT
A
TABLES
A1,
A2,
A3,
and
A4
(
For
Tables
A1
through
A3,
see
Excel
Spreadsheet
EG­
OSWI­
Cost
yrs
1­
6)

Table
A1:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
1
Table
A2:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
2
Table
A3:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
3
Table
A4:
Summary
of
Respondent
Burden
for
Emission
Guidelines
­
Years
1
through
3
TABLE
A4.
SUMMARY
OF
RESPONDENT
BURDEN
FOR
EMISSION
GUIDELINES
­
YEARS
1
THROUGH
3
Non­
Labor
Costs
Year
Technical
Hours
Management
Hours
Clerical
Hours
Contractor
Hours
Total
Hours
Labor
Costs
Capital
O&
M
Total
Cost
Year
1
14,880
744
1,488
0
17,112
$
786,164
0
0
$
786,164
Year
2
0
0
0
0
0
0
0
0
0
Year
3
0
0
0
0
0
0
0
0
0
Totals
14,880
744
1,488
0
17,112
$
786,164
0
0
$
786,164
Average
Burden
Per
Year
4,960
248
496
0
5,704
$
262,055
0
0
$
262,055
Note:
All
figures
are
rounded
to
nearest
dollar
or
hour.
ATTACHMENT
B
TABLES
B1,
B2,
B3,
and
B4
(
For
Tables
B1
through
B3,
see
Excel
Spreadsheet
EG­
OSWI­
Cost
yrs
1­
6)

Table
B1:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
1
Table
B2:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
2
Table
B3:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
3
Table
B4:
Summary
of
Designated
Administrator
Burden
for
Emission
Guidelines
­
Years
1
through
3
TABLE
B4.
SUMMARY
OF
DESIGNATED
ADMINISTRATOR
FOR
EMISSION
GUIDELINES
­
YEARS
1
THROUGH
3
Agency
Burden
Summary:
Technical
Hours
Management
Hours
Clerical
Hours
Total
Hours
Labor
Costs
Year
1
800
40
80
920
$
42,267
Year
2
0
0
0
0
0
Year
3
200
10
20
230
$
10,567
Totals
1,000
50
100
1,150
$
52,834
Average
Burden
Per
Year
333
17
33
383
$
17,611
Note:
All
figures
are
rounded
to
the
nearest
dollar
or
hour.
ATTACHMENT
C
TABLES
C1,
C2
and
C3
(
For
Tables
C1
through
C3,
see
Excel
Spreadsheet
EG­
OSWI­
Cost
yrs
1­
6)

Table
C1:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
4
Table
C2­
A:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
5
(
All
Comply)

Table
C2­
B:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
5
(
All
Close)

Table
C3­
A:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
6
(
All
Comply)

Table
C3­
B:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
6
(
All
Close)
ESTIMATED
RESPONDENT
BURDEN
FOR
YEARS
4,
5,
and
6
The
following
tables
display
the
estimated
respondent
burden
for
the
fourth,
fifth
and
sixth
years
following
promulgation
of
the
OSWI
emission
guidelines
(
40
CFR
60
subpart
FFFF).
These
tables
are
presented
as
an
example
of
the
burden
expected
beyond
the
first
three
years
discussed
in
the
supporting
statement
and
presented
in
attachment
A.

The
burden
increases
in
year
5
because
the
compliance
date
for
the
emission
guidelines
is
5
years
after
promulgation.

Table
C1
presents
the
burden
and
costs
for
year
4
following
promulgation.
During
this
year,
there
are
no
required
activities
such
as
testing,
reporting,

recordkeeping,
etc.
and,
as
such,
no
expected
costs
to
respondents.
We
anticipate
that
any
activities
needed
to
demonstrate
compliance
with
the
emission
guidelines,
such
as
CEMS
installation
and
emissions
testing,
will
not
occur
until
year
5.

Tables
C2­
A
and
C2­
B
present
the
year
5
respondent
burden
and
cost
for
two
possible
scenarios
which
may
occur
with
existing
OSWI
units
 
one
where
all
units
comply
with
the
emission
guidelines
(
C2­
A),
and
another
where
all
units
close
and
utilize
alternative
waste
disposal
options
(
C2­
B).

The
EPA's
experience
with
other
CAA
section
129
regulations
has
shown
that
sources
will
likely
respond
to
the
emission
guidelines
by
choosing
to
shut
down
existing
waste
incineration
units
and
utilizing
alternative
waste
disposal
options
rather
than
incur
the
costs
of
compliance.
The
EPA's
objective
is
not
to
encourage
the
use
of
alternatives
or
to
discourage
continued
use
of
VSMWC
units
or
IWI
units;

EPA's
objective
is
to
adopt
emission
guidelines
for
existing
OSWI
units
that
fulfill
the
requirements
of
CAA
section
129.

In
doing
so,
however,
the
primary
outcome
associated
with
the
adoption
of
these
emission
guidelines
is
projected
to
be
an
increase
in
the
use
of
alternative
waste
disposal
and
a
decrease
in
the
use
of
VSMWC
and
IWI
units.
As
a
result,
we
present
burden
and
cost
estimates
for
both
possible
scenarios
for
existing
OSWI
units.

Table
C2­
A
presents
the
burden
and
cost
associated
with
initial
compliance
demonstration,
including
CEMS
costs
and
the
initial
performance
test,
assuming
that
all
existing
OSWI
units
choose
to
comply
with
the
emission
guidelines.

Table
C2­
B
presents
the
year
5
respondent
burden
and
cost
for
all
existing
OSWI
units,
assuming
that
all
units
close
down
and
utilize
alternative
waste
disposal
options.

The
tables
for
year
6
also
present
the
two
scenarios
presented
for
year
5.
Table
C3­
A
presents
the
year
6
respondent
burden
assuming
that
all
existing
OSWI
units
comply
with
the
emission
guidelines.
Ongoing
compliance
demonstration
activities
and
associated
recordkeeping
and
reporting
activities,
such
as
continuous
monitoring,
annual
emissions
testing,
annual
compliance
reporting,
and
deviation
reporting
are
included.
While
not
shown
on
this
table,
it
is
noteworthy
that
the
emission
guidelines
provide
provisions
for
sources
to
skip
annual
performance
testing
if
they
have
demonstrated
sustained
good
performance
(
i.
e.,
if
you
have
at
least
three
consecutive
annual
tests
that
show
that
you
comply
with
the
emission
limit
for
a
pollutant,

then
you
do
not
have
to
conduct
a
performance
test
for
that
pollutant
for
the
next
2
years).
Therefore,
the
annual
burden
may
decrease
in
later
years
as
sources
become
eligible
for
the
skip
testing
provisions.
Table
C3­
B,
which
shows
no
costs
or
burden,
presents
the
year
6
respondent
burden
assuming
all
existing
OSWI
units
close
down
and
utilize
alternative
waste
disposal
options.
ATTACHMENT
D
TABLES
D1,
D2,
and
D3
(
For
Tables
D1
through
D3,
see
Excel
Spreadsheet
EG­
OSWI­
Cost
yrs
1­
6)

Table
D1:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
4
Table
D2­
A:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
5
(
All
Comply)

Table
D2­
B:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
5
(
All
Close)

Table
D3­
A:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
6
(
All
Comply)

Table
D3­
B:
Annual
Designated
Administrator
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
of
the
Emission
Guidelines
for
OSWI
Facilities
Subject
to
Subpart
FFFF
­
Year
6
(
All
Close)
ESTIMATED
DESIGNATED
ADMINISTRATOR
BURDEN
FOR
YEARS
4,
5,
and
6
The
following
tables
display
the
estimated
Designated
Administrator
burden
for
the
fourth,
fifth
and
sixth
years
following
promulgation
of
the
OSWI
emission
guidelines
(
40
CFR
60
subpart
FFFF).
These
tables
are
presented
as
an
example
of
the
burden
expected
beyond
the
first
three
years
discussed
in
the
supporting
statement
and
presented
in
attachment
B.
The
burden
increases
in
year
5
because
the
compliance
date
for
the
emission
guidelines
is
5
years
after
promulgation.

Table
D1
presents
the
burden
and
costs
for
year
4
following
promulgation.
During
this
year,
the
only
required
Designated
Administrator
activity
is
the
preparation
of
an
annual
summary
report.
We
anticipate
that
activities
needed
to
demonstrate
compliance
with
the
emission
guidelines,
such
as
observing
and
reviewing
initial
performance
tests
and
review
of
final
compliance
reports,
will
not
occur
until
year
5.

Tables
D2­
A
and
D2­
B
present
the
year
5
Designated
Administrator
burden
and
cost
for
two
possible
scenarios
which
may
occur
with
existing
OSWI
units
 
one
where
all
units
comply
with
the
emission
guidelines
(
D2­
A),
and
another
where
all
units
close
and
utilize
alternative
waste
disposal
options
(
D2­
B).
The
EPA's
experience
with
other
CAA
section
129
regulations
has
shown
that
sources
will
likely
respond
to
the
emission
guidelines
by
choosing
to
shut
down
existing
waste
incineration
units
and
utilizing
alternative
waste
disposal
options
rather
than
incur
the
costs
of
compliance.
The
EPA's
objective
is
not
to
encourage
the
use
of
alternatives
or
to
discourage
continued
use
of
VSMWC
units
or
IWI
units;
EPA's
objective
is
to
adopt
emission
guidelines
for
existing
OSWI
units
that
fulfill
the
requirements
of
CAA
section
129.
In
doing
so,
however,
the
primary
outcome
associated
with
the
adoption
of
these
emission
guidelines
is
projected
to
be
an
increase
in
the
use
of
alternative
waste
disposal
and
a
decrease
in
the
use
of
VSMWC
and
IWI
units.
As
a
result,
we
present
burden
and
cost
estimates
for
both
possible
scenarios
for
existing
OSWI
units.

Table
D2­
A
presents
the
burden
and
cost
associated
with
initial
compliance
demonstration,
including
observation
of
the
initial
performance
tests,
review
of
final
compliance
notifications,
waste
management
plan
reviews,
and
initial
compliance
test
report
reviews,
assuming
that
all
existing
OSWI
units
choose
to
comply
with
the
emission
guidelines.

Table
D2­
B
presents
the
year
5
Designated
Administrator
burden
and
cost,
assuming
that
all
units
close
down
and
utilize
alternative
waste
disposal
options.

The
tables
for
year
6
also
present
the
two
scenarios
as
with
year
5.
Table
D3­
A
presents
the
year
6
Designated
Administrator
burden
assuming
that
all
existing
OSWI
units
comply
with
the
emission
guidelines.
Ongoing
compliance
demonstration
activities,
such
as
observing
annual
performance
tests,
review
of
semi­
annual
deviation
reports,

and
review
of
annual
compliance
reports
are
included
in
the
cost
and
burden.
While
not
shown
on
this
table,
it
is
noteworthy
that
the
emission
guidelines
provide
provisions
for
sources
to
skip
annual
performance
testing
if
they
have
demonstrated
sustained
good
performance
(
i.
e.,
if
you
have
at
least
three
consecutive
annual
tests
that
show
that
you
comply
with
the
emission
limitation
for
a
pollutant,
then
you
do
not
have
to
conduct
a
performance
test
for
that
pollutant
for
the
next
2
years).
Therefore,
the
annual
burden
associated
with
observing
annual
performance
tests
may
decrease
in
later
years
as
sources
become
eligible
for
the
skip
testing
provisions.
Table
D3­
B,
which
shows
no
costs
or
burden,
presents
the
year
6
Designated
Administrator
burden
assuming
all
existing
OSWI
units
close
down
and
utilize
alternative
waste
disposal
options.
ATTACHMENT
E
BUREAU
OF
LABOR
STATISTICS
INFORMATION
(
For
the
BLS
Web
site
printouts,
see
Adobe
PDF
file
BLSdata.
pdf)
