SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
CCCC)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
CISWI)
were
proposed
on
November
30,
1999,
and
promulgated
on
December
1,
2000.
This
standard
applies
to
solid
waste
incinerators
in
40
CFR
subpart
CCCC.
These
standards
fulfill
the
requirements
of
Sections
111
and
129
of
the
Clean
Air
Act
(
CAA),
which
require
the
United
States
Environmental
Protection
Agency
(
EPA)
to
promulgate
standards
for
solid
waste
incinerators.

Respondents
are
owners
or
operators
of
solid
waste
incinerators.
This
standard
applies
to
new
stationary
sources,
that
is,
incineration
units
that
meet
either
of
the
two
criteria:
1)
sources
whose
construction
begins
after
the
NSPS
is
proposed,
which
is
November
30,
1999;
or
2)
sources
that
are
reconstructed
or
modified
on
or
after
June
1,
2001.
The
standards
apply
to
the
owner
or
operator
of
a
combustion
device
that
combusts
commercial
and
industrial
waste.
Commercial
and
industrial
waste
is
a
solid
waste
combusted
in
an
enclosed
device
using
controlled
flame
combustion
without
energy
recovery,
which
is
a
distinct
operating
unit
of
any
commercial
or
industrial
facility,
including
field­
erected,
modular,
and
custom­
built
incineration
units
operating
with
starved
or
excess
air,
or
solid
waste
combusted
in
an
air
curtain
incinerator
without
energy
recovery
that
is
a
distinct
operating
unit
of
any
commercial
or
industrial
facility.

The
annual
performance
testing
will
ensure
on
an
ongoing
basis
that
the
air
pollution
control
device
is
operating
properly
and
its
performance
has
not
deteriorated.
To
minimize
the
burden
of
the
annual
performance
testing,
the
rule
only
requires
that
the
owner
or
operator
test
for
particulate
matter
(
PM),
hydrogen
chloride
(
HCl),
and
opacity.
Annual
performance
testing
is
not
required
for
dioxins/
furans,
cadmium
(
Cd),
carbon
monoxide
(
CO),
lead
(
Pb),
mercury
(
Hg),
nitrogen
oxides
(
NOx),
and
sulfur
dioxide
(
SO2).
This
significantly
reduces
the
testing
costs
while
still
providing
the
EPA
with
sufficient
data
to
adequately
assess
compliance.
In
addition,
the
rule
allows
the
owner
or
operator
to
skip
two
annual
tests
for
a
pollutant
if
all
performance
tests
over
the
previous
three
years
show
compliance
with
the
emission
limit.
During
the
initial
performance
test
(
for
PM,
dioxins/
furans,
opacity,
HCl,
Cd,
Pb,
Hg,
CO,
NOx
2
and
SO2),
the
owner
or
operator
must
establish
maximum
or
minimum
values
for
each
operating
parameter.
Thereafter,
the
owner
or
operator
must
conduct
annual
performance
tests
for
PM,
HCl,
and
opacity,
and
continuously
monitor
the
operating
parameters.

Owners
or
operators
subject
to
the
provisions
of
the
subpart
must
perform
the
following
activities:
conduct
performance
tests,
monitor
operating
parameters,
prepare
siting
analysis,
prepare
waste
management
plan,
operator
training
and
qualifications,
one­
time
and
periodic
reports,
and
the
maintenance
of
records.
Reports
are
submitted
semiannually
and
annually.
These
activities
will
enable
EPA
to
determine
initial
compliance
with
emission
standards
for
the
regulated
pollutants,
monitor
compliance
with
operating
parameters,
and
ensure
that
facilities
conduct
the
proper
planning
and
operator
training.
Owners
or
operators
of
CISWI
units
are
required
to
keep
records
of
certain
parameters
and
information
for
a
period
of
five
years.

The
standards
include
annual
operator
training
requirements
for
incinerator
unit
operators
(
rule
requires
at
least
one
qualified
operator
or
supervisor
per
facility).
The
annual
training
requirements
include
annual
refresher
training
to
maintain
operator
qualification
and
an
annual
review
of
site­
specific
documentation.
The
way
in
which
an
incinerator
is
operated
has
a
significant
impact
on
the
emissions
from
that
incinerator.
The
annual
operator
training
is
essential
to
ensure
that
the
incinerator
is
being
operated
properly.
The
rule
contains
flexibility
in
the
operator
training
by
allowing
the
use
of
State­
approved
training
and
qualification
programs.

Records
and
reports
required
by
the
NSPS
for
commercial
and
industrial
solid
waste
incineration
units
are
necessary
to
enable
EPA
to
identify
sources
subject
to
the
standards
and
to
ensure
that
the
standards
are
being
achieved.
Records
and
reports
must
be
maintained
at
the
facility
and/
or
submitted
to
EPA.
All
reports
are
sent
to
the
delegated
State,
local,
or
tribal
agency.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
Regional
office.

Approximately
30
sources
are
currently
subject
to
the
regulation,
based
on
an
estimated
average
increase
of
six
new
sources
each
year
over
the
next
three
years.
The
cost
of
this
ICR
is
estimated
to
be
$
1,325,274.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
current
Information
Collection
Request
(
ICR)
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:
3
.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated.
Section
111(
a)(
l).

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

In
the
Administrator's
judgment,
emissions
from
commercial
and
industrial
solid
waste
incinerators
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
CCCC.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
PM,
HCl,
or
opacity
from
commercial
and
industrial
solid
waste
incineration
units
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
pollutants
from
commercial
and
industrial
solid
waste
incineration
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
pollutant
emissions
using
control
technology
and
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
that
the
pollution
control
devices
are
properly
installed
and
operated,
that
leaks
are
being
detected
and
repaired,
and
that
the
regulations
are
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
records
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirement
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subpart
CCCC.
4
3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
Regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
local
agency.
If
a
State
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
used
several
different
resources
to
obtain
the
most
recent
data
available
for
commercial
and
industrial
solid
waste
incineration
sources.
We
referenced
the
most
recent
ICR
and
the
coordinator
of
the
active
ICR.
We
also
accessed
the
most
recent
data
(
September
30,
2003)
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
accessed
the
United
States
Census
Bureau
via
the
Internet
and
other
web
sites
covering
commercial
and
industrial
sold
waste
incineration.
We
also
consulted
EPA's
Office
of
Air
Quality
Planning
and
Standards
Information
Transfer
and
Program
Integration
Division.
In
addition,
we
contacted
several
trade
associations
and
industry
sources,
as
follow:
1)
Integrated
Waste
Service
Association,
Ms.
Maria
Zanes
at:
(
202)
467­
6240;
Council
of
Industry
Boilers
and
Owners,
Robert
Bessette
at:
(
703)
250­
9042;
Atlantic
Wood
Incorporated,
Robert
Benton
at:
(
912)
964­
1234;
and
Imperial
Fabrication
Co.
Incorporated,
Jeff
Bledsoe
at:
(
615)
325­
9224.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
The
requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
that
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
Part
1320,
Section
1320.5.
5
These
standards
require
affected
facilities
to
maintain
all
records
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
record's
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
and
NAICS
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
commercial
and
industrial
solid
waste
incineration
(
CISWI)
units.
The
SIC
(
United
States
Standard
Industrial
Classification)
codes
which
correspond
to
the
NAICS
(
The
North
American
Industry
Classification
System)
codes
can
be
found
in
the
following
table.

Standard
SIC
Codes
NAICS
Codes
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR,
part
60,
subpart
CCCC)

Manufacturers
of
chemicals
and
allied
products
28
325
6
Manufacturers
of
electronic
equipment
34
325
Manufacturers
of
wholesale
trade,
durable
goods
36
421
Manufacturers
of
lumber
and
wood
furniture
24
321
Manufacturers
of
wholesale
trade,
durable
goods
25
337
4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
Part
1320,
Section
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
New
Source
Performance
Standards
(
NSPS)
for
Commercial
and
Industrial
Solid
Waste
Incineration
(
CISWI)
Units
(
40
CFR
part
60,
subpart
CCCC).

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
preconstruction
(
prior
to
commencing
construction)
including
anticipated
date
of
initial
startup
60.2190
Notification
of
actual
startup
60.2195
Notification
of
initial
performance
test
60.2200
Annual
report
60.2205
and
60.2210
Emission
limitation
or
operating
limit
deviation
report
60.2215
and
60.2220
Qualified
operator
deviation
notification
60.2225(
a)(
1)

Qualified
operator
deviation
status
report
60.2225(
a)(
2)

Qualified
operator
deviation
notification
of
resumed
operation
60.2225(
b)
7
A
source
must
keep
the
following
records:

Recordkeeping
Records
of
initial
performance
tests,
annual
performance
tests,
and
any
subsequent
performance
tests.
60.2175(
f)

Maintain
records
of
days
for
which
data
on
operating
parameters
have
not
been
obtained,
including
operating
parameters
not
measured,
reasons
for
not
measuring,
and
a
description
of
corrective
actions
taken.
60.2175(
c)

Maintain
records
of
occurrence
and
duration
of
malfunction
and
the
corrective
action
taken.
60.2175(
d)

Maintain
records
of
days
when
deviation
from
operating
limits
have
occurred,
and
description
of
corrective
actions
taken.
60.2175(
e)

Maintain
records
of
all
documentation
produced
for
the
siting
analysis.
60.2175(
g)

Maintain
records
of
names
of
persons
who
have
completed
review
of
site­
specific
information
and
incinerator
operating
procedures.
60.2175(
h)
and
60.2095(
a)

Maintain
records
of
names
of
persons
who
have
completed
the
operator
training
requirements.
60.2175(
i)

Maintain
records
of
names
of
phone
and/
or
pager
numbers
of
persons
who
have
met
the
operator
qualification
criteria.
60.2175(
j)

Maintain
records
or
calibration
of
monitoring
devices.
60.2175(
k)

Maintain
records
of
equipment
vendor
specifications
for
the
incinerator,
emission
controls,
and
monitoring
equipment.
60.2175(
l)

Maintain
records
of
daily
log
of
quantity
and
types
of
wastes
burned.
60.2175(
n)

Records
should
be
retained
for
five
years.
60.2175
Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
leaks
and
spills
of
mercury.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
8
regulatory
agencies.
It
is
estimated
that
approximately
10%
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
control
devices
for
PM,
HCl,
and
opacity.

Perform
initial
performance
test,
Reference
Method
1,
3A
or
3B
test,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

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

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

Adjust
the
existing
ways
to
comply
with
previously
applicable
instructions
and
requirements.

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

Transmit
or
otherwise
disclose
the
information.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.
9
Agency
Activities
Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
to
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
offices
and
EPA
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
The
proposed
NSPS
and
Emission
Guidelines
(
EG)
were
intended
to
cover
CISWI
units
burning
industrial
solid
waste,
not
combustors
burning
municipal
solid
waste.
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
CCCC).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
10
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
16,899
(
Total
Labor
Hours
from
Table
1)
per
year.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
89.94
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
61.66
per
hour
for
Technical
labor,
and
$
38.39
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
one,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
89.94
($
42.83
+
110%)
Technical
$
61.66
($
29.36
+
110%)
Clerical
$
38.39
($
18.28
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
subject
standard
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
an
one­
time
cost
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor(
s)
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
11
1
The
capital/
startup
cost
and
O&
M
could
be
found
in
Table
1
under
column
"
Non­
labor
costs
per
occurrence"
and
"
Total
non­
labor
costs
per
year".
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startup
Cost
for
One
Respondent1
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent1
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Wet
Scrubber
$
2,240
6
$
13,440
$
211
24
$
5,064
The
total
capital/
startup
costs
for
this
ICR
are
$
13,440.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
5,064.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
18,000
(
rounded).
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
8,858
(
rounded).
This
cost
is
based
on
the
average
hourly
labor
rate
times
a
1.6
benefit's
multiplication
factor
to
account
for
government
overhead
expenses.
The
rates
are
as
follows:

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
12
1
Annual
report
covers:
a)
site
specific
operating
parameters,
2)
statement
of
no
exceedances,
and
3)
documentation
for
periods
where
all
qualified
operators
were
unavailable
for
more
than
8
hours.

2
Double
counting
of
existing
respondents.

3
Semiannual
report
of
emissions/
parameter
exceedances.
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
CCCC).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
There
are
30
respondents
that
are
currently
subject
to
the
regulation.
Each
respondent
has
one
affected
facility.
Based
on
our
consultations
approximately
six
additional
affected
facilities
will
become
subject
to
the
rule
each
year.
After
one
year,
new
respondents
become
existing
respondents.
On
average,
there
are
six
new
respondents
and
24
existing
respondents
per
year
over
the
three­
year
period
of
this
ICR.

Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
by
Section
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
Reporting
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
60.2205
and
60.2210
6
4
24
11
0
48
60.22402
N/
A
N/
A
2
2
23
0
4
Total
6
4
24
3
0
52
The
number
of
total
respondents
is
30.
This
number
is
the
sum
of
column
A
and
Column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period
(
i.
e.,
the
total
of
the
number
of
new
respondents
over
the
three­
year
period
divided
by
three
years).
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
Total
Annual
Responses
is
52.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table
above.
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
13
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
1,325,274.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
CCCC).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
18,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
325
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
There
is
an
increase
of
5,690
hours
in
the
total
estimated
burden
currently
identified
in
the
OMB
Inventory
of
Approved
ICR
Burdens.
We
have
determined
that
no
new
growth
has
occurred
in
this
source
category
in
the
sector
over
the
period
of
the
ICR,
however,
based
on
the
assumptions
of
incinerator
equipment
life
and
the
frequency
of
replacement,
it
is
assumed
that
six
of
these
units
will
be
replaced
with
six
new
units
each
year.
Only
new
units
are
subject
to
this
ICR.
After
one
year
new
units
become
existing
respondents.
In
addition,
a
revised
hourly
labor
rate
from
the
United
States
Department
of
Labor
resulted
in
an
increase
over
the
three­
year
period
from
the
previous
ICR.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
325
hours
per
response.
Burdens
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
14
An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0025,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
N.
W.,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1514.
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.
When
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0025
and
OMB
Control
Number
2060­
0450
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Annual
Industry
Burden
­
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
CCCC)

Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
Technical
hours)
Emission
Testing
Contractor
Hours
Per
Occurrence
Non­
Labor
Costs
Per
Occurrence
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
a
(
E)
Technical
Hours
Per
Year
@$
61.66
(
CXD)
b
(
F)
Management
Hours
Per
Year
@$
89.94
(
E
x
0.05)
b
(
G)
Clerical
Hours
Per
Year
@$
38.39
(
E
x
0.1)
b
(
H)
Emission
Testing
Contractor
Hours
Per
Year
@

$
100
b
Total
Labor
Costs
Per
Year
b
Total
Non­
Labor
Costs
Per
Year
1.
APPLICATIONS
N/
A
2.
SURVEY
AND
STUDIES
N/
A
3.
REPORTING
REQUIREMENTS
New
Sources
A.
Read
Instructions
c&
d
16
0
$
0
1
16
6
96
5
10
0
$
6,752.96
$
0
B.
Required
Activities
1)
Initial
requirements
c
a)
Initial
stack
test
and
report
(
PM,
dioxins/

furans,
opacity,
HCI,
Pb,
Hg,
SO2)

b)
Establish
and
teach
operator
qualification
course
c
c)
Obtain
operator
qualification
d)
Establish
operating
parameters
(
maximum
and
minimum)

e)
Continuous
parameter
monitoring
(
including
by­
pass
stack)
initial
costs
d,
e
f)
Initial
review
of
site­
specific
information
24
64
72
160
9
Included
in
3B
750
0
0
Included
in
3B
0
$
0
$
0
$
0
$
0
$
2,240
f
1
1
1
1
1
24
64
72
160
9
6
6
6
6
6
144
384
432
960
54
7
19
22
48
2.7
14
38
43
96
5.4
4,500
0
0
0
0
$
460,046.08
$
26,845.12
$
30,266.57
$
67,196.16
$
3,779.79
$
0
$
0
$
0
$
0
$
13,440
2)
Periodic
requirements
g
a)
Annual
stack
test
and
test
report
(
PM,

HCl,
and
Opacity)

b)
Annual
refresher
operator
training
course
c)
Annual
review
of
site­
specific
information
d)
Continuous
parameter
monitoring
(
including
by­
pass
stack)
annual
12
12
8
83
125
0
0
0
$
0
$
0
$
0
$
211
1
1
1
1
12
12
8
83
24
24
24
24
288
288
192
1,992
14.4
14.4
9.6
99.6
28.8
28.8
19.2
199.2
3,000
0
0
0
$
319,974.58
$
19,974.58
$
13,439.23
$
139,432.03
$
0
$
0
$
0
$
5,064
16
Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
Technical
hours)
Emission
Testing
Contractor
Hours
Per
Occurrence
Non­
Labor
Costs
Per
Occurrence
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
a
(
E)
Technical
Hours
Per
Year
@$
61.66
(
CXD)
b
(
F)
Management
Hours
Per
Year
@$
89.94
(
E
x
0.05)
b
(
G)
Clerical
Hours
Per
Year
@$
38.39
(
E
x
0.1)
b
(
H)
Emission
Testing
Contractor
Hours
Per
Year
@

$
100
b
Total
Labor
Costs
Per
Year
b
Total
Non­
Labor
Costs
Per
Year
costs
f
C.
Create
Information
Included
in
3B
D.
Gather
Information
Included
in
3E
E.
Report
Preparation
1)
Report
prior
to
construction
(
includes
siting
analysis)
160
0
$
0
1
160
6
960
48
96
0
$
67,196.16
$
0
2)
Report
prior
to
initial
start­
up
c&
i
a)
Without
site
specific
parameter
petition
6
0
$
0
1
6
6
36
1.8
3.6
0
$
2,519.85
$
0
b)
With
site
specific
parameter
petition
14
0
$
0
1
14
2
28
1.4
2.8
0
$
1,959.89
$
0
3)
Report
of
initial
performance
test
Included
in
3B
4)
Siting
analysis
for
new
units
only
(
establishes
values
for
site­
specific
operating
parameters)
c
8
0
$
0
1
8
6
48
2.4
4.8
0
$
3,359.81
$
0
5)
Waste
management
plan
c
160
0
$
0
1
160
6
960
48
96
0
$
67,196.16
$
0
6)
Annual
Report:

a)
Site
specific
operating
parameters
parameters
were
established
g
8
0
$
0
1
8
24
192
9.6
19.2
0
$
13,439.23
$
0
during
the
initial
stack
test,
highest
maximum
and
lowest
minimum)

b)
Emissions/
parameter
exceedances
and
malfunctions
g
Included
in
3E
0
$
0
1
0
2
0
0
0
0
$
0
$
0
c)
Results
of
stack
tests
conducted
during
the
year
Included
in
3B
d)
Statement
of
no
exceedances
g
8
0
$
0
1
8
22
176
8.8
17.6
0
$
12,319.29
$
0
e)
Documentation
of
use
of
by­
pass
stack
Included
in
6B
f)
Documentation
for
periods
when
all
qualified
operators
were
unavailable
8
0
$
0
1
8
24
192
9.6
19.2
0
$
13,439.23
$
0
for
more
than
8
hours
g
7)
Status
report
for
operators
that
are
off­
site
for
more
than
2
weeks
j
8
0
$
0
1
8
2
16
0.8
1.6
0
$
1,119.93
$
0
8)
Corrective
action
summary
for
operators
that
are
off­
site
for
more
than
2
weeks
j
8
0
$
0
2
16
2
32
1.6
3.2
0
$
2,239.87
$
0
9)
Semiannual
report
of
emissions/
parameter
exceedances
k
24
0
$
0
1
24
2
48
2.4
4.8
0
$
3,359.81
$
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
N/
A
17
Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
Technical
hours)
Emission
Testing
Contractor
Hours
Per
Occurrence
Non­
Labor
Costs
Per
Occurrence
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
a
(
E)
Technical
Hours
Per
Year
@$
61.66
(
CXD)
b
(
F)
Management
Hours
Per
Year
@$
89.94
(
E
x
0.05)
b
(
G)
Clerical
Hours
Per
Year
@$
38.39
(
E
x
0.1)
b
(
H)
Emission
Testing
Contractor
Hours
Per
Year
@

$
100
b
Total
Labor
Costs
Per
Year
b
Total
Non­
Labor
Costs
Per
Year
E.
Record
Information
1)
Records
of
operating
parameters
Included
in
3B
0
$
0
52
0
24
0
0
0
0
$
0
$
0
2)
Records
of
periods
for
which
minimum
amount
of
data
on
operating
parameters
were
not
obtained
0.5
0
$
0
52
26
2
52
2.6
5.2
0
$
3,639.79
$
0
3)
Records
of
malfunction
of
the
unit
1.5
0
$
0
1
1.5
2
3
0.15
0.3
0
$
209.99
$
0
4)
Records
of
exceedances
of
the
operating
parameters
1.5
0
$
0
1
1.5
2
3
0.15
0.3
0
$
209.99
$
0
5)
Records
of
stack
tests
Included
in
3E
6)
Records
of
siting
analysis
Included
in
3E
7)
Records
of
persons
who
have
reviewed
operating
procedures
1
0
$
0
1
1
24
24
1.2
2.4
0
$
1,679.91
$
0
8)
Records
of
persons
who
have
completed
operator
training
1
0
$
0
1
1
24
24
1.2
2.4
0
$
1,679.91
$
0
9)
Records
of
persons
who
meet
operator
qualification
criteria
1
0
$
0
1
1
24
24
1.2
2.4
0
$
1,679.91
$
0
10)
Records
of
monitoring
device
calibration
Included
in
3B
11)
Records
of
site­
specific
documentation
24
0
$
0
1
24
24
576
28.8
57.6
0
$
40,317.69
$
0
F.
Personnel
Training
Included
in
3B
G.
Time
for
Audits
Not
applicable
TOTAL:
8,166
411
822
7,500
$
1,325,274
$
18,504
Total
Hours
Labor
Non­
Labor
Total
Labor
and
No­
Labor
Summary
of
Respondent
Burden
16,899
$
1,325,274
$
18,504
$
1,343,778
Annualized
Capital
and
Startup
$
13,440
$
13,440
O
&
M
Summary
$
5,064
$
5,064
ASSUMPTIONS:

a.
Based
on
a
total
of
112
units
and
a
20
year
lifetime.
112
units/
20
years
=
5.6
which
was
rounded
to
6
units.
Since
there
is
one
unit
per
facility,
this
also
equates
to
6
facilities.

b.
Assume
that
all
tasks
are
to
be
performed
by
managerial,
technical
and
clerical
personnel.
This
ICR
uses
the
following
labor
rates:
$
89.94
for
Managerial
labor,
$
61.66
for
Technical
labor
and
$
38.39
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
We
also
included
contractors
at
$
100.
The
labor
rate
was
also
taken
from
the
above
occupational
and
industry
group
under
Blue­
Collar
occupation,
that
covers
Machine
operators,
and
took
the
rates
from
column
1,
"
Total
compensation."

c.
This
activity
is
based
on
a
one­
time
cost
only.
18
d.
Cost
incurred
by
a
facility
regardless
of
the
number
of
affected
units
at
the
plant.

e.
Based
on
the
"
Revised
Testing
and
Monitoring
Options
and
Costs
for
medical
Waste
Incinerators
(
MWIs)
­
Methodology
and
Assumptions
(
A­
91­
61,
IV­
B­
66),
was
assumed
that
($
300
will
be
for
planning
+
$
500
for
selection)/$
89.94
per
hour
=
9
hours.

f.
Total
capital
cost
of
parameter
monitoring
for
wet
scrubbers
minus
costs
for
planning
and
selecting
equipment
($
300
+
$
500)
equals:
$
18,786
­
$
800
=
$
17,986.
Based
on
0.11746
capital
recovery
factor,
10%
interest
rate
and
20
year
lifetime
of
the
units
=
$
2,113
with
a
1.06
cost
adjustment
=
$
2,240.

g.
Annual
costs
are
not
incurred
until
the
second
year
that
the
units
are
in
operation.

h.
Based
on
memorandum
titled
"
Revised
Testing
and
Monitoring
Options
and
Costs
for
Medical
Waste
Incinerators
(
MWI's)
­
Methodology
and
Assumptions
[
A­
91­
61,
IV­
B­
66].
83
hours
for
reporting.
Operation
and
maintenance
costs
­
$
1,693
*
0.11746
=
$
199.
$
199
*
1.06
cost
adjustment=
$
211.

i
Assumed
that
one­
third
of
the
facilities
will
petition
for
site­
specific
parameters
(
6
x
33%
=
2)

j
Assumed
that
10
percent
of
the
facilities
would
not
have
a
qualified
operator
available
for
more
than
two
weeks
at
least
once
a
year.
Assumed
that
this
required
only
two
corrective
action
summaries.

k
Assumed
that
10
percent
of
the
facilities
would
have
an
exceedance
during
the
year.
19
TABLE
2:
AVERAGE
Annual
EPA
Burden
­
NSPS
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,

subpart
CCCC)
BURDEN
ITEMS
(
A)
Hours
Per
Occurrences
(
B)
Number
of
Occurrence
Per
Year
(
C)
Tech
Hours
Per
Year
@
$
39.49
(
C=
AxB)
a
(
D)
Management
Hours
Per
Year
@
$
53.22
(
D=
Cx0.05)
a
(
E)
Clerical
Hours
Per
Year
@
$
21.38
(
E=
Cx0.1)
a
(
F)
Cost
Per
Year
(
b)
e
1.
Applications
N/
A
2.
Read
and
Understand
Rule
Requirements
a&
c
16
0
0
0
0
$
0
3.
Required
Activities
A.
Observe
initial
stack
tests
b&
c
(
PM,
dioxins/
furans,
opacity,
HCl,
Cd,
Pb,
Hg,
CO,
NOx,
and
SO2)
48
0
0
0
0
$
0
B.
Excess
emissions
­­
Enforcement
Activities
24
0
0
0
0
$
0
C.
Create
Information
N/
A
D.
Gather
Information
N/
A
E.
Report
Reviews
1)
Review
control
plan
c
8
0
0
0
0
$
0
2)
Review
notification
of
final
compliance
c
8
0
0
0
0
$
0
3)
Review
waste
management
plan
c
8
0
0
0
0
$
0
4)
Review
initial
stack
test
report
c
40
0
0
0
0
$
0
5)
Review
annual
compliance
report
8
0
0
0
0
$
0
6)
Review
semi­
annual
excess
emission
and
parameter
exceedance
report
16
0
0
0
0
$
0
7)
Review
status
reports
and
corrective
action
summary
for
operators
off­
site
4
0
0
0
0
$
0
F.
Prepare
annual
summary
report
d
4
50
200
10
20
$
8,857.80
4
Travel
expenses:
(
1
person
x
30
hours
per
year/
8
hours
per
day
x
$
75
per
diem)
+
($
600
per
round
trip)
$
0
TOTAL
200
f
10
f
20
f
$
8,858
Assumptions:

a.
Costs
are
based
on
the
following
rates
obtained
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay:

1)
Managerial
at
$
33.26,
2)
Technical
at
$
24.68,
and
3)
Clerical
at
$
13.36
per
hour.
These
rates
are
increased
by
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses.

b.
Time
required
to
observe
initial
stack
tests
(
hours
per
plant):
48
c.
This
is
a
one­
time
only
costs.

d.
Assume
that
each
State
will
prepare
an
annual
summary
of
progress
for
implementing
the
state
plan.
One
occurrence
per
year
x
50
states
=
50
occurrences.

e.
Total
costs
per
year
may
not
correspond
with
the
end
total,
this
is
due
to
the
number
being
rounded.
Total
cost
per
year:
$
8,858.

f.
Total
number
of
EPA
hours
per
year:
230
20
