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

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Emissions
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
DDDD)

1(
b)
Short
Characterization/
Abstract
The
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
(
CISWI)
Units
were
promulgated
on
December
1,
2000.
This
standard
applies
to
solid
waste
incinerators
in
40
CFR
part
60,
subpart
DDDD.
These
standards
fulfill
the
requirements
of
Sections
111
and
129
of
the
Clean
Air
Act
(
CAA).
This
subpart
affects
the
Administrator
of
an
air
quality
program
in
a
State
or
United
States
protectorate
with
one
or
more
existing
CISWI
units
that
commenced
construction
on
or
before
November
30,
1999.

The
emissions
guidelines
require:
a
one­
time
waste
management
plan;
initial
performance
tests
for
ten
pollutants;
annual
performance
testing
for
particulate
matter
(
PM),
hydrogen
chloride
(
HCl),
and
opacity;
continuous
operating
parameter
monitoring;
annual
operator
training;
and
annual
reporting.
A
semiannual
deviation
report
is
required
if
any
of
the
emission
limitations
or
operating
limits
are
exceeded.
The
frequency
of
these
activities
was
chosen
by
the
United
States
Environmental
Protection
Agency
(
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
standards.

This
supporting
statement
addresses
information
collection
activities
imposed
by
the
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
(
CISWI)
Units,
subpart
DDDD.
The
guidelines
do
not
apply
directly
to
CISWI
unit
owners
and
operators.
The
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
approved
State
plan,
the
EPA
must
develop
a
Federal
plan
to
implement
the
emission
guidelines.
In
the
event
that
a
State's
plan
is
not
approved,
then
a
Federal
plan
must
be
developed.

The
information
will
be
used
by
designated
Administrator's
enforcement
personnel
to
ensure
that
the
requirements
of
the
State
(
or
Federal)
plans
are
implemented
and
are
complied
with
on
a
continuous
basis.
Specifically,
the
information
will
be
used
by
the
designated
2
Administrator
to:
1)
identify
existing
sources
subject
to
the
standards;
2)
ensure
those
existing
sources
have
a
control
plan
to
achieve
compliance
by
the
final
compliance
date;
3)
ensure
that
subpart
DDDD
is
being
properly
applied;
4)
ensure
that
the
emission
standards
are
being
complied
with;
and
5)
ensure,
on
a
continuous
basis,
that
the
operating
parameters
established
during
the
initial
stack
test
are
not
exceeded.

In
addition,
records
and
reports
are
necessary
to
enable
the
Designated
Administrator
to
identify
CISWI
units
that
are
not
in
compliance
with
the
standards.
Based
on
reported
information,
the
designated
Administrator
can
decide
which
CISWI
units
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
the
CISWI
unit.
The
records
that
CISWI
units
maintain
would
indicate
to
the
designated
Administrator
whether
personnel
are
operating
and
maintaining
the
control
equipment
properly
and
whether
they
have
met
the
qualification
requirements.
In
more
than
95
percent
of
the
cases,
the
enforcement
of
emission
guidelines
has
been
delegated
to
the
State
air
pollution
control
agencies.
In
such
cases,
the
reports
required
by
the
standards
will
be
submitted
to
the
appropriate
State
agency,
and
not
directly
to
the
EPA.
Thus,
there
is
a
minimal
possibility
for
the
duplication
of
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
CISWI
facility.
The
plant
owner
or
operator
may
submit
a
copy
of
State
or
local
reports
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards,
as
specified
in
the
General
Provisions
of
40
CFR
part
60.

With
the
exception
of
requiring
records
to
be
maintained
for
more
than
three
years,
none
of
the
guidelines
in
5
CFR
Part
1320,
Section
1320.5
are
being
exceeded.
This
rule
requires
all
records
to
be
maintained
at
the
source
for
a
period
of
five
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
Act,
CISWI
facilities
are
subject
to
similar
MACT­
based
regulations,
therefore
this
five­
year
record
retention
requirement
was
adopted
for
CISWI
facilities.

There
is
an
annual
average
of
97
respondents
that
will
be
subject
to
the
standard.
In
the
active
ICR,
it
was
assumed
that
most
of
the
burdens
of
the
rule
in
conformity
with
the
initial
requirements
will
not
occur
until
years
four
or
five
of
implementation
of
this
rule.
Therefore,
most
of
the
respondent
burden
for
those
requirements
is
included
in
this
ICR.
The
average
annual
labor
cost
of
this
ICR
will
be
$
5,922,476.

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(
d)(
1)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to:
3
.
.
.
prescribe
regulations
which
shall
establish
a
procedure
similar
to
that
provided
by
section
110
under
which
each
State
shall
submit
to
the
Administrator
a
plan
which
(
A)
establishes
standards
of
performance
for
any
existing
source
for
any
air
pollutant
(
i)
for
which
air
quality
criteria
have
not
been
issued
or
which
is
not
included
on
a
list
published
under
section
108(
a)
.
.
.
but
(
ii)
to
which
a
standard
of
performance
under
this
section
would
apply
if
such
existing
source
were
a
new
source,
and
(
B)
provides
for
the
implementation
and
enforcement
of
such
standards
of
performance.

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

Section
129(
a)(
1)(
A)
states:

The
Administrator
shall
establish
performance
standards
and
other
requirements
pursuant
to
section
111
and
this
section
for
each
category
of
solid
waste
incineration
units.
Such
standards
shall
include
emissions
limitations
and
other
requirements
applicable
to
new
units
and
guidelines
(
under
section
111(
d)
and
this
section)
and
other
requirements
applicable
to
existing
units.

Section
129(
a)(
2)
states:

Standards
applicable
to
solid
waste
incineration
units
promulgated
under
section
111
and
this
section
shall
reflect
the
maximum
degree
of
reduction
in
emissions
of
air
pollutants
listed
under
section
(
a)(
4)
that
the
Administrator,
taking
into
consideration
the
cost
of
achieving
such
emission
reduction,
and
any
non­
air
quality
health
and
environmental
impacts
and
energy
requirements,
determines
is
achievable
for
new
or
existing
units
in
each
category.

Section
129(
b)(
1)
states:

Performance
standards
under
this
section
and
section
111
for
solid
waste
incineration
units
shall
include
guidelines
promulgated
pursuant
to
section
111(
d)
and
this
section
applicable
to
existing
units.
Such
guidelines
shall
include,
as
provided
in
this
section,
each
of
the
elements
required
by
subsection
(
a)
(
emissions
limitations,
notwithstanding
any
restriction
in
section
111(
d)
regarding
issuance
of
such
limitations),
subsection
(
c)
(
monitoring),
subsection
(
d)
(
operator
training),
subsection
(
e)
(
permits),
and
subsection
(
h)(
4)
(
residual
risk).
4
Subpart
B
of
40
CFR
part
60
requires
State
plans
to
include
monitoring,
recordkeeping,
and
reporting
provisions
consistent
with
the
emission
guidelines.
In
addition,
Section
114(
a)(
1)
states
that:

the
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source,
who
manufactures
emission
control
equipment
or
process
equipment,
who
the
Administrator
believes
may
have
information
necessary
for
the
purposes
set
forth
in
this
subsection,
or
who
is
subject
to
any
requirement
of
this
Act
(
other
than
a
manufacturer
subject
to
the
provisions
of
section
206(
c)
or
208
with
respect
to
a
provision
of
title
II)
on
a
one­
time,
periodic
or
continuous
basis
to
­

(
A)
establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods
and
in
such
manner
as
the
Administer
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information,
as
the
Administrator
may
reasonably
require;
.
.
.
.

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
standards
are
being
achieved.
Therefore,
the
emission
guidelines
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
DDDD.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
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
5
Designated
Administrator
to:
(
1)
identify
existing
sources
subject
to
the
standards;
(
2)
ensure
that
those
existing
sources
have
a
control
plan
to
achieve
compliance
by
the
final
compliance
date;
(
3)
ensure
that
subpart
DDDD
is
being
properly
applied;
(
4)
ensure
that
the
emission
standards
are
being
complied
with;
(
5)
ensure,
on
a
continuous
basis,
that
the
operating
parameters
established
during
the
initial
performance
test
are
not
exceeded.

In
addition,
records
and
reports
are
necessary
to
enable
the
Designated
Administrator
to
identify
CISWI
units
that
may
not
be
in
compliance
with
the
standards.
Based
on
reported
information,
the
Designated
Administrator
can
decide
which
CISWI
units
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
the
CISWI
unit.
The
records
that
CISWI
units
maintain
would
indicate
to
the
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
The
requested
recordkeeping
and
reporting
are
required
under
(
40
CFR
part
60,
subpart
DDDD).

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
a
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
requirement
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
preparer
of
the
active
ICR.
We
also
accessed
the
most
recent
data
(
September
30,
2003)
available
on
the
Air
Facility
System
(
AFS)
database
as
6
maintained
by
the
Office
of
Compliance.
We
also
accessed
the
United
States
Census
Bureau
via
the
Internet,
and
other
web
sites
covering
commercial
and
industrial
sold
waste
incineration.
We
consulted
with
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division.
In
addition,
we
contacted
trade
associations
and
industry
sources,
as
follows:
1)
Integrated
Waste
Service
Association,
Ms.
Maria
Zanes,
(
202)
467­
6240;
Council
of
Industry
Boilers
and
Owners,
Robert
Bessette,
(
703)
250­
9042;
Atlantic
Wood
Incorporated,
Robert
Benton,
(
912)
964­
1234;
and
Imperial
Fabrication
Company
Incorporated,
Jeff
Bledsoe,
(
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.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
on
a
less
frequent
basis,
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.

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
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
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
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,
7
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
United
States
Standard
Industrial
Classification
(
SIC)
codes
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
codes
could
be
found
in
the
following
table.

Standard
SIC
Codes
NAICS
Codes
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR,
part
60,
subpart
DDDD)

Manufacturers
of
chemicals
and
allied
products
28
325
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
Law
enforcement
agencies
9229
922
Department
of
Defense
(
labs,
military
bases,
munition
facilities)
9711
928
Research
centers
8221
6113
8
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
the
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
(
CISWI)
Units
(
40
CFR
part
60,
subpart
DDDD).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
of
final
control
plan
60.2600(
a)

Notification
of
final
compliance
60.2605
Submit
waste
management
plan
60.2755
Notification
of
initial
performance
test
60.2760
Notification
of
closure
60.2615
Annual
report
60.2765
and
60.2770
Emission
limitation
or
operating
limit
deviation
report
60.2775,
and
60.2780
Qualified
operator
deviation
notification
60.2785
Notification
of
resumed
operation
60.2785(
b)

Notification
until
increment
is
met
60.2595
A
source
must
keep
the
following
records:
9
Recordkeeping
Records
of
initial
performance
tests,
annual
performance
tests,
and
any
subsequent
performance
tests.
60.2740(
f)

Maintain
records
of
days
for
which
data
on
operating
parameters
have
been
obtained.
Includes
a
list
of
operating
parameters
not
measured,
reason
for
not
measuring,
and
a
description
of
corrective
actions
taken.
60.2740(
c)

Maintain
records
of
occurrence
and
duration
of
any
malfunction
and
the
corrective
action
taken.
60.2740(
d)

Maintain
records
of
days
when
deviation
from
operating
limits
has
occurred,
and
description
of
corrective
actions
taken.
60.2740(
e)

Maintain
records
of
names
of
persons
who
have
completed
review
of
site­
specific
information
and
incinerator
operating
procedures.
60.2740(
g)
and
60.2660(
c)

Maintain
records
of
names
of
persons
who
have
completed
the
operator
training
requirements.
60.2740(
h)

Maintain
records
of
phone
and/
or
pager
numbers
of
persons
who
have
met
the
operator
qualification
criteria.
60.2740(
i)

Maintain
records
of
calibration
of
monitoring
devices.
60.2740(
j)

Maintain
records
of
equipment
vendor
specifications
for
the
incinerator,
emission
controls,
and
monitoring
equipment.
60.2740(
k)

Maintain
records
of
daily
log
of
quantity
and
types
of
waste
burned.
60.2740(
m)

Maintain
records
of
site­
specific
information
and
incinerator
operation
procedures.
60.2660(
c)

Maintain
records
of
operating
parameters.
60.2740(
b)

Maintain
calendar
date
of
each
record.
60.2740(
a)

Records
should
be
retained
for
five
years.
60.2740
Electronic
Reporting
Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way
(
e.
g.,
leaks
and
spills
of
mercury).
Personnel
at
the
source
will
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
reduces
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
10
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,
9,
23,
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
any
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.
11
Agency
Activities
Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
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
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.

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).
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.

The
rules
contain
several
provisions
that
reduce
the
impact
of
the
rule
on
all
regulated
entities,
which
include
small
entities.
These
are:
annual
performance
testing
is
only
required
for
three
pollutants
rather
than
the
full
ten
pollutants
included
in
the
initial
performance
tests;
operating
parameter
monitoring
is
required
instead
of
continuous
emissions
monitoring
systems
12
(
CEMS);
the
owner
or
operator
is
allowed
to
skip
two
annual
performance
tests
for
a
pollutant
if
all
performance
tests
over
the
previous
three
years
show
compliance;
and
deviation
reports
are
only
required
if
there
is
a
deviation,
otherwise
reporting
is
annual.

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

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
a
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
72,423
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
Emissions
Guidelines
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor,
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
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
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)
13
1
The
capital/
startup
costs
and
O&
M
could
be
found
in
Table
1
under
column
"
Non­
labor
costs
per
occurrence
per
respondent"
and
"
Total
non­
labor
costs
per
year".
Section
3B(
1e)
and
(
2d).

2
See
Section
6(
d)
for
calculation.

3
We
have
assumed
that
the
annual
O$
M
cost
are
$
211
per
year.
(
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
cost
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one
time
cost
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Capital/
Startup
Cost
for
One
Respondent1
(
B)
Number
of
Initial
Respondents
2
(
C)
Total
Capital/
Startu
p
Cost,
(
AxB)
(
D)
Annual
O&
M
Costs
for
One
Respondent
3
(
E)
Number
of
Respondents
with
O&
M
2
(
F)
Total
O&
M,
(
ExF)
(
G)
Total
(
C+
F)

$
2,240
39
$
87,360
$
211
58
$
12,238
$
99,598
The
total
capital/
startup
costs
for
this
ICR
are
$
87,360.
This
is
the
total
of
column
C
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
$
12,238.
This
is
the
total
of
column
F.
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
$
99,000
(
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
14
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
$
185,083
(
rounded).
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
1.6
benefits
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"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
Emissions
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
DDDD).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
there
is
an
average
of
97
respondents
currently
subject
to
the
standard.
However,
based
on
assumptions
of
incinerator
equipment
life
and
the
frequency
of
CISWI
replacement,
it
is
assumed
that
six
existing
units
will
be
replaced
with
six
new
units
each
year.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
Initial
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
with
Initial
requirements
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
58
0
0
0
58
2
58
58
0
0
116
3
0
116
0
0
116
Average
39
58
0
0
97
To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
97.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.
15
1
Each
existing
respondent
submits
an
annual
report,
10%
submit
an
operator
status
notification
of
resumed
operation,
10
%
submit
a
corrective
action
summary
report,
and
10%
submit
a
semiannual
exceedance
report.
Total
number
of
reports
per
respondent
is
1.4
per
year.
The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)
Number
of
Initial
Respondents
(
B)
Number
of
Reports
for
Initial
Respondents
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Respondents
(
F)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)

39
5
58
1.41
0
276.2
The
number
of
Total
Annual
Responses
is
276
(
rounded).
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
5,922,476.
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,
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
DDDD).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
99,000.
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
is
estimated
to
average
262
(
rounded)
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burdens
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
In
the
active
ICR,
it
was
assumed
that
most
of
the
burdens
of
the
rule
in
conformity
with
the
initial
requirements
will
not
occur
until
years
four
or
five
of
implementation
of
this
rule.
Therefore,
most
of
the
respondent
burden
for
those
requirements
is
included
in
this
renewal
package.
This
ICR
includes
burdens
associated
with
existing
sources
which
complies
with
initial
requirements.

There
was
no
capital
cost
or
operational
and
maintenance
costs
associated
with
the
emissions
guidelines
in
the
active
ICR,
therefore,
the
respondent
burden
for
the
active
ICR
is
16
minimal,
as
compared
to
the
renewal
ICR.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
262
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA'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
0028,
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
0028
and
OMB
Control
Number
2060­
0451
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.

Table
1:
Annual
Industry
Burden
­
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
DDDD)
17
Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
Technical
hours)
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
(
E)
Technical
Hours
Per
Year
@$
64.13
(
CXD)
b
(
F)
Management
Hours
Per
Year
@$
93.09
(
E
x
0.05)
b
(
G)
Clerical
Hours
Per
Year
@$
39.65
(
E
x
0.1)
b
(
H)
Total
Labor
Costs
Per
Year
b
(
I)
Emission
Testing
Contractor
Hours
Per
Occurrence
per
Respondent
(
J)
Emission
Testing
Contractor
Hours
Per
Year
(
DxI)
(
K)

Non­
Labor
Costs
Per
Occurrence
per
Respondent
Total
Contractor/

Non­
Labor
Costs
Per
Year
(
DxK)
+

(
Jx$
100)
k
1.
APPLICATIONS
N/
A
2.
SURVEY
AND
STUDIES
N/
A
3.
REPORTING
REQUIREMENTS
New
Sources
A.
Read
Instructions
c&
d
16
1
16
0
0
0
0
$
0
0
0
$
0
$
0
B.
Required
Activities
1)
Initial
requirements
a,
c
a)
Initial
stack
test
(
PM,
dioxins/

furans,
opacity,
HCl,
Pb,
Hg,
SO2)

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

e)
Continuous
parameter
monitoring
(
including
by­
pass
stack)
initial
costs
16
64
72
160
9
e
1
1
1
1
1
16
64
72
160
9
39
a
39
a
39
a
39
a
39
a
624
2,496
2,808
6,240
351
31.2
124.8
140.4
312
17.55
62.4
249.6
280.8
624
35.1
$
45,395.69
$
181,582.75
$
204,280.60
$
453,956.88
$
25,535.08
700
0
0
Included
in
3B
(
a)

0
27,300
0
0
0
0
$
0
$
0
$
0
$
0
$
2,240
f
$
2,730,000
$
0
$
0
$
0
$
87,360
2)
Periodic
requirements
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
costs
12
12
8
83
1
1
1
1
12
12
8
83
58
g
58
g
58
g
58
g
696
696
464
4,814
34.8
34.8
23.2
240.7
69.6
69.6
46.4
481.4
$
50,633.65
$
50,633.65
$
33,755.77
$
350,216.09
125
0
0
0
7,250
0
0
0
$
0
$
0
$
0
$
211
h
$
725,000
$
0
$
0
$
12,238
C.
Create
Information
Included
in
3B
D.
Gather
Information
Included
in
3E
E.
Report
Preparation
1)
Control
plan
2)
Notification
of
final
compliance
3)
Report
of
initial
performance
test
40
4
8
1
1
1
40
4
8
39
39
39
1,560
156
312
78
7.8
15.6
156
15.6
31.2
$
113,489.22
$
11,348.92
$
22,697.84
0
0
50
0
0
1,950
$
0
$
0
$
0
$
0
$
0
$
195,000
4)
Siting
analysis
for
new
units
only
(
established
values
for
site­
specific
operating
parameters
5)
Waste
management
plan
8
160
1
1
8
160
39
39
312
6,240
15.6
312
31.2
624
$
22,697.84
$
453,956.88
0
0
0
0
$
0
$
0
$
0
$
0
6)
Annual
Report:
g
a)
Site
specific
operating
parameters
(
parameters
were
established
8
1
8
58
464
23.2
46.4
$
33,755.77
0
0
$
0
$
0
during
the
initial
stack
test,
highest
18
Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
Technical
hours)
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
(
E)
Technical
Hours
Per
Year
@$
64.13
(
CXD)
b
(
F)
Management
Hours
Per
Year
@$
93.09
(
E
x
0.05)
b
(
G)
Clerical
Hours
Per
Year
@$
39.65
(
E
x
0.1)
b
(
H)
Total
Labor
Costs
Per
Year
b
(
I)
Emission
Testing
Contractor
Hours
Per
Occurrence
per
Respondent
(
J)
Emission
Testing
Contractor
Hours
Per
Year
(
DxI)
(
K)

Non­
Labor
Costs
Per
Occurrence
per
Respondent
Total
Contractor/

Non­
Labor
Costs
Per
Year
(
DxK)
+

(
Jx$
100)
k
maximum
and
lowest
minimum)

b)
Emissions/
parameter
exceedances
and
malfunctions
Included
in
3E
10
c)
Results
of
stack
tests
conducted
during
the
year
Included
in
3B
d)
Statement
of
no
exceedances
8
1
8
58
464
23.2
46.4
$
33,755.77
0
0
$
0
$
0
e)
Documentation
of
use
of
by­
pass
stack
Included
in
6B
f)
Documentation
for
periods
when
all
qualified
operators
were
unavailable
8
1
8
58
464
23.2
46.4
$
33,755.77
0
0
$
0
$
0
for
more
than
8
hours
7)
Status
report
for
operators
that
are
off­

site
for
more
than
2
weeks
i
8
1
8
6
48
2.4
4.8
$
3,491.98
0
0
$
0
$
0
8)
Corrective
action
summary
for
operators
that
are
off­
site
for
more
than
2
weeks
i
8
2
16
6
96
4.8
9.6
$
6,983.95
0
0
$
0
$
0
9)
Qualified
operator
deviation
notification
of
resumed
operation
8
1
8
6
48
2.4
4.8
$
3,491.98
0
0
$
0
$
0
10)
Semiannual
report
of
emissions/
parameter
exceedances
j
24
1
24
6
144
7.2
14.4
$
10,475.93
0
0
$
0
$
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
E.
Record
Information
1)
Records
of
operating
parameters
Included
in
3B
0
$
0
2)
Records
of
periods
for
which
minimum
amount
of
data
on
operating
parameters
were
not
obtained
0.5
52
26
6
156
7.8
15.6
$
11,348.92
0
0
$
0
$
0
3)
Records
of
malfunction
of
the
unit
1.5
1
1.5
6
9
0.45
.9
$
654.76
0
0
$
0
$
0
4)
Records
of
exceedances
of
the
operating
parameters
1.5
1
1.5
6
9
0.45
.9
$
654.76
0
0
$
0
$
0
5)
Records
of
stack
tests
Included
in
3E
6)
Records
of
persons
who
have
reviewed
operating
procedures
1
1
1
58
58
2.9
5.8
$
4,219.47
0
0
$
0
$
0
7)
Records
of
persons
who
have
completed
operator
training
1
1
1
58
58
2.9
5.8
$
4,219.47
0
0
$
0
$
0
8)
Records
of
persons
who
meet
operator
qualification
criteria
1
1
1
58
58
2.9
5.8
$
4,219.47
0
0
$
0
$
0
9)
Records
of
monitoring
device
calibration
Included
in
3B
10)
Records
of
site­
specific
documentation
24
1
24
58
1,392
69.6
139.2
$
101,267.30
0
0
$
0
$
0
F.
Personnel
Training
Included
in
3B
19
Burden
Item
(
A)
Respondent
Hours
per
Occurrence
(
Technical
hours)
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Hours
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
(
E)
Technical
Hours
Per
Year
@$
64.13
(
CXD)
b
(
F)
Management
Hours
Per
Year
@$
93.09
(
E
x
0.05)
b
(
G)
Clerical
Hours
Per
Year
@$
39.65
(
E
x
0.1)
b
(
H)
Total
Labor
Costs
Per
Year
b
(
I)
Emission
Testing
Contractor
Hours
Per
Occurrence
per
Respondent
(
J)
Emission
Testing
Contractor
Hours
Per
Year
(
DxI)
(
K)

Non­
Labor
Costs
Per
Occurrence
per
Respondent
Total
Contractor/

Non­
Labor
Costs
Per
Year
(
DxK)
+

(
Jx$
100)
k
G.
Time
for
Audits
N/
A
TOTAL:
31,237
1,562
3,124
$
2,272,475.70
36,500
$
3,749,598
Labor
Hours
Contractor
Labor
Hours
Total
Hours
Labor
Cost
Contractor/

Non­
Labor
Cost
Total
Cost
Summary
of
Respondent
Burden
Annual
Capital/
Startup
Costs
O
&
M
Summary
35,923
36,500
72,423
$
2,272,476
$
3,650,000
$
87,360
$
12,238
$
5,922,476
$
87,360
$
12,238
ASSUMPTIONS:

a.
Based
on
a
total
of
122
units
and
a
20
year
lifetime
of
the
equipment
(
122
units/
20
years
=
6.1
which
was
rounded
to
6
units),
we
assume
there
is
one
unit
per
facility,
this
also
equates
to
6
facilities
that
will
become
new
sources
not
subject
to
this
standard.
Hence,
the
average
number
of
respondents
per
year
over
the
three
year
period
of
the
renewal
is
97.
We
have
assumed
that
50%
of
existing
sources
(
number
of
sources
over
three
years
is116)
will
submit
initial
requirements
in
year
one
and
year
two
for
and
average
of
39
initial
respondents
per
year.
By
the
third
year
of
this
ICR
renewal
all
sources
(
116)
would
have
complied
with
the
initial
requirements.

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.

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
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.
Of
116
respondents,
zero
have
periodic
or
annual
reports
the
first
year,
58
will
report
the
second
year
and
116
report
the
third
year
for
an
average
of
58
respondents
per
year.
Each
respondent
makes
one
combined
annual
report
per
year.

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
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.

j.
Assumed
that
10
percent
of
the
facilities
would
have
an
exceedance
during
the
year.

k.
Average
cost
for
contractor
is
assumed
to
be
$
100.
per
hours.
20
TABLE
2:
AVERAGE
Annual
EPA
Burden
­
Emission
Guidelines
for
Commercial
and
Industrial
Solid
Waste
Incineration
Units
(
40
CFR
part
60,
subpart
DDDD)
BURDEN
ITEMS
(
A)
Hours
Per
Occurrences
(
B)
Number
of
Occurrence
Per
Year
a
(
C)
Tech
Hours
Per
Year
@
$
39.49
(
C=
AxB)
b
(
D)
Management
Hours
Per
Year
@
$
53.22
(
D=
Cx0.05)
b
(
E)
Clerical
Hours
Per
Year
@
$
21.38
(
E=
Cx0.1)
b
(
F)
Cost
Per
Year
1.
Applications
N/
A
2.
Read
and
Understand
Rule
Requirements
b
16
0
0
0
0
$
0
3.
Required
Activities
A.
Observe
initial
stack
tests
c
(
PM,
dioxins/
furans,
opacity,
HCl,
Cd,
Pb,
Hg,
CO,
NOx,
and
SO2)
48
4
192
9.6
19.2
$
8,503.49
B.
Create
Information
N/
A
C.
Gather
Information
N/
A
D.
Report
Reviews
1)
Review
control
plan
8
39
312
15.6
31.2
$
13,818.17
2)
Review
notification
of
final
compliance
8
39
312
15.6
31.2
$
13,818.17
3)
Review
waste
management
plan
8
39
312
15.6
31.2
$
13,818.17
4)
Review
initial
stack
test
report
40
39
1,560
78
156
$
69,090.84
5)
Review
annual
compliance
report
8
39
312
15.6
31.2
$
13,818.17
6)
Review
semi­
annual
excess
emission
and
parameter
exceedance
report
16
39
624
31.2
62.4
$
27,636.33
7)
Review
status
reports
and
corrective
action
summary
for
operators
off­
site
4
39
156
7.8
15.6
$
6,909.09
E.
Prepare
annual
summary
report
d
4
50
200
10
20
$
8,857.80
4
Travel
expenses:
(
10
person
x
30
hours
per
year/
8
hours
per
day
x
$
75
per
diem)
+
(
10
x
$
600
per
round
trip)
e
$
8,812.50
TOTAL
3,980
f
199
f
398
f
$
185,083
(
rounded)
g
Assumptions:

a.
Based
on
a
total
of
122
units
and
a
20
year
lifetime.
110
units/
20
years
=
6
.1
which
was
rounded
to
6
units.
There
is
one
unit
per
facility,
this
also
equates
to
6
facilities.

b.
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.

c.
Time
required
to
observe
initial
stack
tests
(
hours
per
plant):
48
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.
We
have
assumed
that
10%
of
tests
will
be
observed.

f.
Total
number
of
EPA
hours
per
year:
4,577
g.
Total
costs
per
year
may
not
correspond
with
the
end
total,
this
is
due
to
the
number
being
rounded.
Total
cost
per
year:
$
185,083.
