STANDARD
FORM
83
SUPPORTING
STATEMENT
FOR
ICR
NO.
1847.02
­­
FEDERAL
PLAN
REQUIREMENTS
FOR
LARGE
MUNICIPAL
WASTE
COMBUSTORS
CONSTRUCTED
ON
OR
BEFORE
SEPTEMBER
20,
1994
(
SUBPART
FFF)

RENEWAL
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
NC
27711
OCTOBER
2001
2
PART
A
OF
THE
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83
Municipal
Waste
Combustors
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
Title
of
the
Information
Collection.

"
Federal
plan
reporting
and
recordkeeping
requirements
for
large
municipal
waste
combustors."
This
is
a
renewal
and
has
been
assigned
tracking
number
EPA
ICR
1847.02
for
years
4,
5
and
6.

(
b)
Characterization
of
Information
Collection.

This
supporting
statement
addresses
information
collection
activities
that
would
be
imposed
by
the
proposed
"
Federal
Plan
Requirements
for
Large
Municipal
Waste
Combustors
(
MWC's)
Constructed
on
or
before
September
20,
1994,"
40
CFR
62
subpart
FFF
(
MWC
Federal
plan).
This
information
collection
renewal
is
required
as
a
result
of
a
Federal
plan
to
implement
and
enforce
the
Clean
Air
Act
(
CAA)
emission
guidelines
(
40
CFR
part
60
subpart
Cb)
for
large
municipal
waste
combustors
(
MWC's)
that
were
promulgated
under
the
authority
of
CAA
sections
111
and
129.
The
emission
guidelines
are
not
Federally
enforceable.
Under
the
CAA
section
129(
b)(
2),
States
were
required
to
submit
State
plans
to
the
Environmental
Protection
Agency
(
EPA)
for
approval
by
December
19,
1996
that
implement
and
enforce
the
guidelines.
Section
129(
b)(
3)
requires
EPA
to
promulgate
a
Federal
plan
to
implement
and
enforce
the
guidelines
in
those
States
that
have
not
submitted
an
approvable
plan
to
EPA
by
December
19,
1997.
Reporting
and
recordkeeping
requirements
would
apply
to
MWC
units
with
capacities
to
combust
greater
than
250
tons
per
day
(
tpd)
(
large
MWC's).
The
EPA
Regional
Offices
will
collect
the
required
information
(
after
promulgation
of
the
MWC
Federal
plan)
to
ensure
that
the
subpart
FFF
Federal
plan
is
being
implemented
and
enforced
for
affected
facilities
in
States
that
have
not
submitted
an
approvable
State
plan.

Reduced
dioxin/
furan
testing
Although
no
burden
reduction
credit
is
being
taken
on
this
SF­
83
for
MWC
plants
that
are
eligible
for
the
following
provision,
it
should
be
noted
that
a
provision
for
less
frequent
dioxin/
furan
testing
is
included
in
the
MWC
Federal
plan.
This
provision
allows
plants
to
test
only
one
unit
per
year
rather
than
all
units,
as
is
normally
required,
if
all
units
at
the
plant
achieve
emission
levels
less
than
the
emission
limit
for
2
consecutive
years.
It
is
believed
that
most
units
will
qualify
for
this
option.
As
most
plants
have
2
or
more
units,
this
provision
will
reduce
dioxin
testing
frequency,
costs,
and
burden
by
at
least
one
half
starting
in
the
third
year
after
the
compliance
date
of
the
affected
facility
specified
in
the
MWC
Federal
plan.
3
2.
AUTHORITY/
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
Authority/
Need
for
the
Collection.

The
EPA
is
required
under
section
129
of
the
CAA,
as
amended,
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
of
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).

Section
129
also
requires
EPA
to
develop
a
Federal
plan
to
enforce
the
emission
guidelines
for
any
State
that
has
not
submitted
an
approvable
State
plan
by
December
19,
1997.
Section
129(
b)(
3)
is
the
legal
authority
for
the
MWC
Federal
plan.

Section
129(
b)(
3)
States:
The
Administrator
shall
develop,
implement,
and
enforce
a
plan
for
existing
solid
waste
incineration
units
within
any
category
located
in
any
State
which
has
not
submitted
an
approvable
plan
under
this
subsection
with
respect
to
units
in
such
category
within
2
years
after
the
date
on
which
the
Administrator
promulgated
the
relevant
guidelines.

Section
129
is
reproduced
in
Attachment
1.
Certain
reports
and
records
are
necessary
to
ensure
that
the
MWC
Federal
plan
requirements
are
being
achieved
on
a
continuous
basis.
4
(
b)
Use/
Users
of
the
Data.

The
information
will
be
used
by
the
Agency
to
ensure
that
the
MWC
Federal
plan
requirements
are
implemented
and
are
complied
with
on
a
continuous
basis
through
proper
operation
and
maintenance
of
the
emission
control
device.

In
addition,
records
and
reports
are
necessary
to
enable
EPA
to
identify
MWC
units
that
may
not
be
in
compliance
with
the
MWC
Federal
plan
requirements.
Based
on
reported
information,
EPA
will
decide
which
plants
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
the
plants.
The
records
that
plants
maintain
will
indicate
to
EPA
whether
plant
personnel
are
operating
and
maintaining
control
equipment
properly.

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

A
computer
search
of
EPA's
ongoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.
This
Federal
plan
will
apply
to
MWC's
in
States
that
do
not
have
an
approved
State
plan.
In
those
cases
where
States
have
not
been
delegated
authority
to
implement
and
enforce
the
MWC
Federal
plan,
yet
still
require
information
from
the
MWC
plant,
the
plant
owner
or
operator
may
submit
a
copy
of
the
State
or
local
reports
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
plan,
if
the
same
information
is
provided.

(
b)
Public
notice
prior
to
ICR
submission
to
OMB.

A
public
notice
of
this
collection
was
provided
in
the
notice
of
proposed
rulemaking
published
on
August
17,
2001,
66FR43253.
A
comment
was
received
from
Mark
Strohfus,
Great
River
Energy,
17845
E.
Hwy
10,
P.
O.
Box
800,
Elk
River,
MN
55330­
0800.
Mr.
Strohfus
wanted
to
know
if
EPA
plan
to
increase
the
monitoring,
recordkeeping,
or
reporting
burden
of
large
municipal
waste
combustors?
EPA's
responded
to
Mr.
Strohfus
as
follows:
Yes.
A
table
is
attached
to
the
ICR
for
Subpart
FFF
that
shows
burden
level
by
year.
Subpart
FFF
is
implemented
over
a
number
of
years
and
the
burden
increases
with
time
as
air
pollution
control
retrofits
and
CEMS
retrofits
are
completed.
In
the
first
three
year
period,
the
burden
is
minimal
as
the
air
pollution
control
retrofits
and
CEMS
retrofits
are
underway,
but
not
completed.
During
the
next
three
year
period,
the
burden
increases
as
MWCs
come
into
compliance.
By
the
third
three
year
period,
steady
state
burden
level
is
achieved.
All
of
these
burden
estimates
are
attached
to
the
original
ICR
that
was
approved
by
OMB.

(
c)
Consultations.
5
The
proposed
MWC
Federal
plan
includes
the
same
recordkeeping
and
reporting
requirements
as
the
subpart
Cb
emission
guidelines.
An
important
element
in
the
efforts
to
solicit
public
comments
when
developing
the
regulation
in
1988
was
the
review
of
staff
technical
analyses
and
policy
recommendations
by
the
National
Air
Pollution
Control
Techniques
Advisory
Committee
(
NAPCTAC).
This
advisory
committee
comprises
representatives
of
State
and
local
governments,
regulated
industries,
environmental
organizations,
and
technical
consultants
with
expertise
in
air
pollution
control
technologies.
Prior
to
the
December
20,
1989
proposed
subpart
Ea
NSPS
for
MWC
plants,
presentations
to
NAPCTAC
were
made
on
May
18,
1989
and
June
7,
1989
to
solicit
the
views
of
committee
members
and
interested
members
of
the
public.
To
provide
interested
persons
the
opportunity
for
oral
presentation
of
data,
views,
or
arguments
regarding
the
December
20,
1989
proposed
standards,
public
hearings
were
held
in
Boston,
Massachusetts,
on
January
22
and
23,
1990;
in
Detroit,
Michigan,
on
January
25
and
26,
1990;
and
in
Seattle,
Washington,
on
January
30
and
31,
1990.
These
hearings
were
open
to
the
public,
and
the
public
was
given
the
opportunity
to
comment
on
the
proposed
standards.
The
public
comment
period
for
the
December
20,
1989
proposed
standards
was
from
December
20,
1989
to
March
1,
1990.
Over
300
comment
letters
were
received,
and
about
100
interested
parties
testified
at
the
public
hearing.

On
January
31,
1991,
presentations
were
made
to
NAPCTAC
to
solicit
their
views
on
the
additional
requirements
to
be
added
to
the
standards
through
proposal
of
subparts
Eb
and
Cb,
including
standards
for
cadmium
(
Cd),
lead
(
Pb),
mercury
(
Hg),
and
siting.
Additionally,
after
the
subpart
Eb
NSPS
and
the
subpart
Cb
emission
guidelines
were
proposed
on
September
20,
1994,
152
letters
commenting
on
the
proposed
standards
and
guidelines
were
received.
Comments
were
provided
by
industry
representatives,
governmental
entities,
environmental
groups,
and
private
citizens.
Though
the
comment
period
officially
lasted
from
September
20,
1994
through
November
21,
1994,
one­
third
of
the
comment
letters
received
and
considered
by
EPA
were
received
after
November
21,
1994.
After
consideration
of
the
comments,
subparts
Eb
and
Cb
were
promulgated
on
December
19,
1995.

The
Federal
plan
contains
the
same
testing,
monitoring,
recordkeeping
and
reporting
requirements
as
subparts
Eb
and
Cb.
Section
60.39b
of
subpart
Cb,
promulgated
in
December
1995,
requires
that
for
a
State
plan
to
be
approved,
it
must
contain
the
recordkeeping
and
reporting
requirements
of
subpart
Eb.
Because
this
Federal
plan
will
be
promulgated
in
lieu
of
State
plans
for
MWC's
in
States
that
do
not
have
approved
State
plans,
this
Federal
plan
must
also
contain
the
same
recordkeeping
and
reporting
as
subparts
Eb
and
Cb.
Public
comments
on
the
Federal
plan
requirements
are
solicited
by
the
proposal
notice.

(
d)
Effects
of
Less
Frequent
Data
Collection.

The
Federal
plan
requirements
include
a
combination
of
annual
emission
testing
and
continuous
monitoring
with
an
abbreviated
annual
report
(
more
detailed
semiannual
6
reports
if
any
emission
limits
are
exceeded)
for
demonstrating
compliance
with
the
air
emissions
standards.
The
frequency
of
these
reports
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
standards.

Continuous
monitoring
provides
assurance
of
continuous
control
of
acid
gas
emissions
and
is
an
enforcement
policy
of
EPA.
Either
sulfur
dioxide
(
SO2)
or
hydrogen
chloride
(
HCl),
or
both
could
be
monitored;
however,
continuous
monitoring
devices
for
HCl
are
not
readily
available
and
are
more
expensive
than
SO2
monitors.
Further,
it
was
determined
that
continuous
monitoring
of
SO2
with
an
annual
performance
test
for
HCl
will
adequately
ensure
that
sources
are
achieving
continuous
compliance.

Annual
testing
and
reporting
of
particulate
matter
(
PM),
HCl,
Cd,
Pb,
Hg,
and
opacity,
in
combination
with
continuous
monitoring
of
opacity,
will
determine
reduction
in
MWC
metal
emissions.
In
addition,
quarterly
monitoring
of
carbon
usage
will
help
ensure
continuous
compliance
with
the
Hg
emission
limit.
Less
frequent
testing
and
reporting
would
not
ensure
continuous
compliance.

An
annual
stack
test
and
report
of
the
measured
emission
level
for
dioxin/
furan
emissions
is
necessary
to
demonstrate
control
of
organic
emissions.
However,
less
frequent
dioxin/
furan
testing
is
possible
for
plants
if
all
affected
facilities
at
a
plant
consistently
achieve
emission
levels
lower
than
the
emission
limit.
Additionally,
quarterly
monitoring
of
carbon
usage
will
help
ensure
continuous
compliance
with
the
dioxin/
furan
emission
limit.

Continuous
monitoring
of
MWC
operating
parameters
(
CO,
load,
temperature)
is
a
part
of
good
combustion
practices
(
GCP)
and
is
the
best
method,
together
with
quarterly
monitoring
of
carbon
usage,
to
ensure
continuous
reduction
in
organic
emissions
from
MWC's.

(
e)
General
Guidelines.

With
the
exception
of
requiring
records
to
be
maintained
for
more
than
3
years,
none
of
the
guidelines
in
CFR
1320.5
are
being
exceeded.
This
Federal
plan,
which
implements
the
emission
guidelines,
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.
Under
section
129
of
the
CAA
Amendments
of
1990,
MWC
facilities
are
subject
to
similar
MACT­
based
regulations,
such
that
this
5­
year
record
retention
requirement
was
adopted
for
MWC
facilities.
Furthermore,
section
129
requires
all
MWC
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.
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.
7
(
f)
Confidentiality
and
Sensitive
Questions.

(
i)
Confidentiality.
All
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
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

(
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
(
a)
Respondents/
NAICS
Codes.

Respondents
are
owners
or
operators
of
existing
municipal
waste
combustors
with
a
capacity
to
combust
greater
than
250
tons
per
day
that
are
located
in
those
States
that
have
not
yet
received
EPA
approval
of
State
plans.
The
MWC
Federal
plan
requirements
affect
North
American
Industry
Classification
System
(
NAICS)
Code
92411,
Air
and
Water
Resource
and
Solid
Waste
Management
(
formerly
SIC
Code
9511,
Air
and
Water
Resource
and
Solid
Waste
Management),
and
NAICS
Code
562213,
Solid
Waste
Combustors
and
Incinerators
(
formerly
SIC
Code
4953,
Refuse
Systems).
The
1997
NAICS
replaces
the
1987
Standard
Industrial
Code
system.

(
b)
Information
Requested.

(
i)
Data
items.
Attachment
2,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements
of
this
regulation.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
standards
are
provided
under
the
first
column
of
table
1,
introduced
in
section
6(
a).
All
burden
tables
are
included
in
Attachment
3.

(
iii)
Summary
of
Federal
plan
requirements.
For
years
4,
5
and
6
(
renewal)
emission
controls
were
installed
at
the
end
of
year
3.

As
the
means
for
determining
compliance
with
the
MWC
Federal
plan
requirements
for
MWC
acid
gases,
MWC
metals,
MWC
organics,
and
GCP,
owners
or
operators
of
affected
facilities
are
required
to
collect
the
information
specified
in
subpart
Cb,
keep
records,
and
submit
reports.
Owners
or
operators
are
required
to
conduct
compliance
tests
and
compliance
demonstrations
for
all
pollutants
and
parameters,
as
well
as
continuous
monitoring
or
annual
retests
of
all
pollutants
and
parameters,
unless
the
owner
or
operator
qualifies
for
less
frequent
dioxin/
furan
testing,
as
described
below.
8
Continuous
monitoring
of
SO2,
nitrogen
oxides
(
NOx),
opacity,
carbon
monoxide
(
CO),
load
level,
temperature
of
the
flue
gas
stream,
and
oxygen
(
O2)
or
carbon
dioxide
(
CO2)
is
required.
Annual
retests
for
PM,
dioxin/
furan,
opacity,
HCl,
Cd,
Pb,
Hg,
and
fugitive
ash
emissions
are
required.
As
a
means
of
determining
continuous
compliance
for
Hg
and
dioxin/
furan,
owners
or
operators
are
required
to
keep
records
of
the
quarterly
amount
of
carbon
used
for
activated
carbon
injection
and
to
calculate
the
estimated
hourly
carbon
injection
rate
for
hours
of
operation.

Owners
or
operators
of
affected
facilities
are
required
to
submit
an
initial
compliance
report
for
all
regulated
pollutants
and
parameters.
Once
a
year,
owners
or
operators
of
affected
facilities
are
required
to
submit
an
annual
report
for
all
regulated
pollutants
and
parameters
that
summarizes
data
collected
for
all
pollutants
and
parameters
regulated
by
the
MWC
Federal
plan.
Owners
or
operators
are
required
to
submit
an
annual
report
that
indicates
the
highest
emission
level
established
during
the
annual
test
or
recorded
using
continuous
emissions
monitoring
systems
(
CEMS)
for
SO2,
NOx,
CO,
MWC
unit
load
level,
PM
control
device
inlet
temperature,
and
opacity.
If
the
emission
level
recorded
for
any
of
these
pollutants
shows
emissions
above
the
emission
limit
for
the
pollutant
or
a
calculated
carbon
injection
rate
below
the
carbon
injection
rate
established
during
the
Hg
or
dioxin/
furan
annual
retest,
then
the
owner
or
operator
is
required
to
submit
a
semiannual
report
for
the
calendar
half
during
which
the
test
was
conducted
or
data
were
collected,
and
the
report
is
required
to
include
the
supporting
data
or
test
report
and
an
explanation
for
the
exceedence.
Owners
or
operators
are
not
required
to
submit
test
reports
or
raw
CEMS
data
unless
a
pollutant
or
parameter
is
recorded
as
exceeding
the
emission
limit
for
the
pollutant
or
parameter.

As
described
above,
a
provision
for
less
frequent
dioxin/
furan
testing
is
included
in
the
MWC
Federal
plan.
It
is
believed
that
most
affected
facilities
will
qualify
for
this
option.
As
most
plants
have
2
or
more
affected
facilities,
this
option
to
reduce
testing
frequency
will
reduce
costs
and
burden
for
dioxin/
furan
by
one
half
starting
in
the
third
year
after
compliance.
This
SF­
83
burden
estimate
does
not
reflect
this
reduced
burden.

Under
the
MWC
Federal
plan,
owners
or
operators
of
affected
facilities
are
required
to
keep
records
of
certain
parameters
and
information.
These
records
include:


Employees'
names
and
dates
of
their
initial
and
annual
review
of
the
sitespecific
operating
manual.


Rates
and
parameters
using
CEMS
for
NOx,
SO2,
CO,
and
O2
or
CO2,
and
continuous
opacity
monitors
for
opacity
levels.


Continuous
measurements
of
MWC
unit
load
and
PM
control
device
temperature,
and
computation
of
average
emissions
and
operating
parameters.
9

The
date
and
operating
parameters
of
any
opacity
level
exceedences,
with
reasons
and
a
description
of
corrective
action.


Results
of
daily
SO2,
NOx,
and
CO
CEMS
drift
tests
and
quarterly
Appendix
F
accuracy
assessments.


Records
of
initial
performance
tests
and
all
annual
performance
retests
for
compliance
with
PM,
dioxin/
furan,
HCl,
Cd,
Pb,
and
Hg
limits.


Records
of
periodic
testing
for
fugitive
ash
emissions.

All
records
are
required
to
be
maintained
at
the
source
for
a
period
of
5
years.
Refer
to
section
3(
e)
for
justification
of
this
5­
year
recordkeeping
requirement.

All
reports
required
under
the
MWC
Federal
plan
are
to
be
submitted
to
the
applicable
EPA
Regional
Office.
The
information
will
be
used
to
determine
that
all
sources
subject
to
the
MWC
Federal
plan
are
achieving
the
requirements.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION,
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
section
6(
c)
and
in
table
2
of
Attachment
3.

(
b)
Collection
Methodology
and
Management.

See
section
5(
d)
Collection
Schedule.

(
c)
Small
Entity
Flexibility.

The
Agency
considers
a
small
business
in
the
MWC
industry
to
be
one
with
annual
gross
revenue
less
than
$
6
million,
and
a
small
government
to
be
one
that
serves
a
population
less
than
50,000.
The
135
MWC
units
potentially
affected
by
the
Federal
plan
are
not
owned
by
small
businesses
or
non­
profit
organizations.
Large
MWC
units
affected
by
the
MWC
Federal
plan
serve
a
population
greater
than
50,000,
therefore
no
small
governments
are
affected
by
this
proposed
rule.
It
would
take
an
MWC
unit
with
half
the
capacity
of
those
affected
by
the
MWC
Federal
plan
to
serve
a
community
of
about
50,000.
For
example,
an
MWC
unit
with
123
tons
per
day
capacity
would
serve
a
community
of
50,000
if
each
person
generates
1.8
kg
of
MSW
per
day
and
sends
all
of
it
to
the
MWC
plant,
which
would
be
operated
at
80
percent
of
capacity.
The
MWC
Federal
plan
affects
only
MWC
units
with
a
capacity
greater
than
250
tons
per
day
(
225
Mg/
day)
and
therefore
affects
no
small
businesses
and
no
small
governments.
10
(
d)
Collection
Schedule.

Information
collected
in
this
renewal
includes,
annual
compliance
tests
for
dioxin/
furan,
PM,
opacity,
HCl,
Cd,
Pb,
Hg,
and
fugitive
ash
emissions.
Continuous
monitoring
is
required
for
SO2,
NOx,
CO,
CO2
or
O2,
load,
temperature
of
the
flue
gas
stream,
and
opacity.
For
all
of
the
regulated
pollutants,
a
brief
annual
report
listing
the
highest
pollutant
emission
level
recorded
for
all
tested
and
monitored
pollutants
is
required.
Additionally,
if
any
pollutant
emission
limit
is
exceeded,
a
semi­
annual
report
providing
test
and
monitoring
data
and
explanation
of
the
exceedence
is
required.

The
EPA
intends
to
prepare
annual
progress
reports
on
the
implementation
and
enforcement
of
the
MWC
Federal
plan.
Information
obtained
from
annual
compliance
reports
will
be
published
and
distributed
through
the
CDS.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
for
internal
EPA
use
in
compliance
with
enforcement
programs.

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

Based
on
a
1995
MWC
inventory
and
recent
information
from
EPA
Regional
Offices,
this
Federal
plan
is
projected
to
affect
135
MWC
units
at
56
plants
in
19
States.
The
respondent
burden
expected
to
result
from
implementation
of
the
MWC
Federal
plan
reflects
a
scenario
in
which
all
but
three
States
have
approved
State
plans.
Table
1
presents
an
itemized
breakdown
of
the
reporting
and
recordkeeping
requirements
for
the
respondents
subject
to
this
Federal
plan.
(
All
burden
tables
are
included
in
Attachment
3.)
The
annual
cost
and
labor
burden
estimates
for
reporting
and
recordkeeping
are
also
presented
in
table
1.
These
numbers
were
derived
from
estimates
based
on
the
1995
MWC
inventory,
previous
subparts
Ea
and
Eb
rulemakings,
EPA's
experience
with
other
standards,
and
the
ESD
Manual
on
burden
estimates.

The
burden
estimate
is
based
on
five
States.
The
years
4,
5
and
6
burden
estimate
includes
24
affected
units
at
8
plants
in
three
States.
See
Docket
Item
A­
97­
45,
II­
I­
7
"
Status
of
Section
111(
d)/
129
State
Plans
for
Large
MWC
Units"
for
a
summary
of
State
plan
submittals.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
these
requirements
are
presented
in
table
1.
The
total
cost
for
each
respondent
activity
comprises
labor
costs,
capital/
startup
costs,
and
operating
and
maintenance
(
O&
M)
costs.

(
i)
Labor
costs,
on
a
per­
hour
basis,
are
based
on
those
posted
on
the
Bureau
of
Labor
Statistics
(
BLS)
web
site
(
http://
state.
bls.
gov/
news.
release)
as
of
March
1998.
11
The
occupational
category
that
is
the
most
similar
to
personnel
at
MWC
plants
is
assumed
to
be
"
electric,
gas,
and
sanitary
services,
blue­
collar
occupations"
for
technical
personnel
and
"
service
producing
industries"
(
which
includes
utilities)
for
management
and
clerical
personnel.
Those
labor
rates
are
$
20.01
for
technical
personnel,
$
24.15
for
management
personnel,
and
$
11.37
for
clerical
personnel.
The
labor
rates
are
adjusted
with
an
average
fringe
benefit
rate
of
140
percent
to
account
for
paid
leave,
insurance,
etc.
This
fringe
benefit
rate
is
determined
by
averaging
the
BLS
fringe
benefit
rates
for
similar
occupational
categories.
The
labor
rates
are
also
adjusted
by
an
overhead
and
profit
rate
of
167
percent.
Therefore,
the
total
"
loaded"
wage
rates
are
calculated
by
the
following
equation:

base
labor
rate
x
1.40
x
l.
67
=
"
loaded"
wage
rate
Given
the
fringe
benefit
and
cost
overhead
adjustments,
the
final
total
"
loaded"
wage
rates
are
$
46.78
for
technical
personnel,
$
56.46
for
management
personnel,
and
$
26.58
for
clerical
personnel.
A
copy
of
the
sections
used
from
the
President's
report
is
provided
in
Attachment
4.

(
ii)
Estimating
Capital/
Start­
up
Costs.
Capital
costs
associated
with
this
Federal
plan
result
from
the
installation
of
CEMS.
All
MWC
plants
(
except
for
those
subject
to
subpart
Ea)
must
install
CEMS
to
collect
the
information
required
by
EPA.
CEMS
are
required
for
monitoring
sulfur
dioxide,
nitrogen
oxides,
opacity,
carbon
monoxide,
and
carbon
dioxide
or
oxygen
in
the
MWC
exhaust
stream.
Start­
up
costs
result
from
initial
CEMS
demonstrations
and
from
initial
emission
performance
tests
for
PM,
dioxin/
furans,
opacity,
fugitives,
HCl,
Pb,
Hg,
and
Cd.
It
is
assumed
that
all
MWC
plants
will
contract
a
testing
company
to
provide
sampling
and
analytical
services
for
air
emissions
testing.
Based
on
EPA's
experience
with
CEMS
installation,
CEMS
performance
demonstrations,
and
with
manual
measurement
methods,
the
estimated
cost
for
each
of
these
activities
is
as
follows:


CEMS
Installation
(
SO2,
NOx,
Opacity,
CO,
CO2
or
O
2)
=
$
100,000

Initial
CEMS
performance
demonstration
=
$
37,200

Initial
Manual
Emission
Tests
(
PM,
dioxins,
opacity,
fugitives,
HCl,
Cd,
Pb,
Hg)
=
$
48,500

Initial
Manual
Emission
Tests
for
units
subject
to
subpart
Ea
(
fugitives,
Cd,
Pb,
Hg)
=
$
16,760
Given
the
requirements
of
the
Federal
plan,
the
estimated
total
annualized
capital
and
startup
costs
for
the
affected
units
averaged
over
the
first
3
years
are
$
3,513,000.

(
iii)
Total
Operation
and
Maintenance
(
O&
M),
and
Purchase
of
Service
Costs.
Costs
associated
with
O&
M
and
purchase
of
service
costs
include
daily
CEMS
calibration,
12
quarterly
CEMS
audits,
and
annual
manual
method
compliance
tests
(
PM,
dioxins,
opacity,
fugitives,
HCl,
Cd,
Pb,
Hg).

As
part
of
O&
M
costs,
MWC
plants
will
calibrate
the
CEMS
daily
and
audit
the
CEMS
quarterly.
Operation
and
maintenance
costs
include
purchasing
calibration
gases
and
performing
daily
calibrations
and
quarterly
appendix
F
audits.
Facilities
also
will
have
to
conduct
one
relative
accuracy
test
audit
(
RATA)
per
year
for
the
CEMS.
The
costs
for
CEMS
O&
M
are
as
follows:


Daily
calibration
=
$
40,150
per
year

Quarterly
performance
audits
=
$
8,925
per
quarter

RATA
=
$
37,200
per
year
Costs
for
each
annual
manual
method
performance
test
are
the
same
as
the
initial
manual
method
tests
presented
in
section
6(
b)(
ii)
of
this
supporting
statement.

The
estimated
total
operation,
maintenance,
and
purchase
of
services
costs
averaged
over
the
first
3
years
are
expected
to
be
$
58,915.
This
estimated
cost
includes
the
installation
of
CEMS,
quarterly
audits
of
the
CEMS,
and
annual
manual
method
performance
tests.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
additional
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
sections
111
and
129
of
the
CAA,
no
operational
costs
would
be
incurred
by
the
Federal
Government.
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
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
could
not
be
attributable
to
the
ICR.
The
only
costs
that
the
Federal
Government
would
incur
are:
user
costs
associated
with
the
analysis
of
the
reported
information;
on­
site
observation
of
the
initial
CEMS
demonstrations
and
initial
performance
tests
and
retests;
and
the
preparation
of
an
annual
report
summarizing
the
compliance
status
of
all
the
affected
facilities.
These
are
presented
in
table
2.

Labor
rates
for
the
Federal
employees
are
based
on
the
estimated
hourly
rates
of
$
40.33
for
technical
personnel
(
GS­
12,
Step
5);
$
66.66
for
management
personnel
(
GS­
15,
Step
5);
and
$
22.73
for
clerical
personnel
(
GS­
7,
Step
5).
These
values
represent
the
inclusion
of
a
l.
6
multiplier
to
account
for
overhead
and
fringe
benefit
costs.
13
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs.

The
total
number
of
respondents
also
is
referred
to
as
the
respondent
universe.
The
respondent
universe
for
this
ICR
is
based
on
a
1995
MWC
inventory
and
recent
information
from
EPA
Regional
Offices.
The
respondents
universe
has
not
changed
since
1995,
therefore,
there
has
been
no
industry
growth.
The
industry
burden
is
calculated
for
135
MWC
units
at
56
plants.
As
described
below,
the
burden
to
the
respondent
universe
varies
among
the
activities
because
not
all
respondents
must
complete
each
activity.

The
Agency
estimates
that
9
of
the
units
at
4
plants
affected
by
the
Federal
plan
are
already
subject
to
subpart
Ea,
and
would
incur
costs
only
for
the
subpart
Cb
requirements
that
are
beyond
the
requirements
of
subpart
Ea.
Three
Ea
units
at
one
plant
are
expected
to
be
affected
by
the
Federal
plan
during
the
4,
5
and
6
year.

Additional
estimates
regarding
the
respondent
universe
are
included
in
the
industry
burden
determinations.
EPA
estimates
that
twenty
percent
of
all
respondents
will
repeat
initial
performance
tests
due
to
failure
and
eight
percent
will
do
semi­
annual
excess
emissions
tests.
Also,
EPA
estimates
that
approximately
fifty
percent
of
the
respondents
will
complete
retrofit
and
conduct
initial
performance
testing
during
Year
2
and
will
begin
annual
performance
tests
and
reports
and
quarterly
appendix
F
audits
of
CEMS
during
Year
3.
Also
during
Year
3,
these
respondents
will
begin
recordkeeping
for
affected
MWC
units.
The
remaining
fifty
percent
will
complete
their
retrofit
and
conduct
initial
performance
tests
in
Year
3.
The
percentage
estimates
are
based
on
the
previous
subparts
Ea
and
Eb
rulemakings,
EPA's
experience
with
other
standards,
and
the
ESD
Manual
on
burden
estimates.

(
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
Federal
plan
is
presented
in
table
1.
The
estimate
of
total
annual
hours
requested
from
the
respondents
was
based
on
the
assumptions
outlined
in
section
6(
d)
of
this
supporting
statement.
The
EPA
estimated
the
respondent
burden
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff
for
the
4,
5
and
6
years
of
this
Federal
plan
and
then
dividing
that
total
by
three.
A
similar
approach
was
taken
for
estimating
annual
labor
costs.
For
the
next
4th,
5th
and
6th
year,
the
implementation
of
the
Federal
plan,
EPA
estimates
that
industry
would
expend
58,915
hours
annually
at
a
cost
of
$
3,218,400
per
year
to
meet
the
monitoring,
recordkeeping,
and
reporting
requirements.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
table
2,
are
calculated
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff
(
as
specified
for
respondents),
and
by
totaling
the
cost
column.
The
estimated
average
annual
burden,
over
years
4,
5
and
6,
for
the
Agency
would
be
3625
hours
at
a
cost
of
$
172,187
(
including
travel
expenses)
per
year.
14
Years
4,
5
and
6
burden
includes
initial
testing.
Also
during
Year
3
initial
testing
and
reporting
and
appendix
F
CEMS
audits.
Respondent
hours
in
Year
3
is
58,915
(
technical,
managerial,
and
clerical).
The
total
cost
(
labor
plus
non­
labor)
for
all
Year
3
respondents
is
$
10,941,000.

(
f)
Reasons
for
change
in
burden.

By
the
third
three
year
period,
the
burden
level
is
achieved.
Due
to
State
Plan,
number
of
respondents
will
remain
at
56.
Since
1995,
labor
rates
have
changed
as
reflected
in
Tables
1
and
2.
(
Renewal)

(
g)
Burden
Statement.

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.

Send
comments
on
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
a
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
Ms
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822),
Offfice
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­
0001;
and
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.
Include
the
EPA
ICR
number
1847.02
and
OMB
Control
Number
2060­
0390
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
1
Section
129
of
the
Clean
Air
Act
ATTACHMENT
2
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
ATTACHMENT
2
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Federal
plan
Regulation
Reference
(
40
CFR
62)
40
CFR
Subpart
Eb
Cross­
Reference
RECORDKEEPING
5­
year
retention
of
records
62.39b(
a)
60.59b(
d)
(
e)

Records
of
CEMS
rates
and
parameters
and
computations
of
average
emissions
and
parameters.
62.39b(
a)
60.59b(
d)

Records
of
initial
performance
tests
and
annual
performance
tests.
62.39b(
a)
60.59b(
d)

Records
of
results
of
daily
CEMS
drift
tests
and
Appendix
F
accuracy
assessments.
62.39b(
a)
60.59b(
d)

Records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
of
the
facility
or
any
malfunction
of
the
CEMS.
62.39b(
a)
n/
a
Records
of
quarterly
amount
of
sorbent
used
for
Hg
control.
62.39b(
a)
60.59b(
d)

Records
of
names
of
persons
who
have
completed
review
of
operating
manual.
62.39b(
a)
60.59b(
d)
ATTACHMENT
2
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
(
Continued)

Requirement
Federal
plan
Regulation
Reference
(
40
CFR
62)
40
CFR
Subpart
Eb
Cross­
Reference
REPORTING
Notification
of
completion
of
each
increment
of
progress.
62.39b(
a)
n/
a
Notification
of
initial
performance
tests
(
PM,
dioxin/
furan,
opacity,
HCl,
Cd,
Pb,
Hg,
fugitives).
60.8(
d)
of
General
Provisions
n/
a
Report
initial
performance
tests
for
all
regulated
pollutants
and
parameters.
62.39b(
a)
60.59b(
f)

Report
of
CEMS
demonstration
and
test
data.
62.39b(
a)
60.59b(
f)

Annual
compliance
reports
for
all
pollutants
and
parameters.
62.39b(
a)
60.59b(
g)

Semiannual
excess
emission
reports
(
SO2,
CO,
load,
temperature,
PM,
dioxin/
furan,
opacity,
HCl,
Cd,
Pb,
Hg,
fugitives).
62.39b(
a)
60.59b(
h)
ATTACHMENT
3
RESPONDENT
AND
FEDERAL
GOVERNMENT
BURDEN
AND
COST
OF
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
OF
SUBPART
FFF
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
OF
THE
FEDERAL
PLAN
FOR
EXISTING
MWC
UNITS
SUBJECT
TO
SUBPART
FFF
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
OF
THE
FEDERAL
PLAN
FOR
EXISTING
MWC
UNITS
SUBJECT
TO
SUBPART
FFF
(
CONTINUED)
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
OF
THE
FEDERAL
PLAN
FOR
EXISTING
MWC
UNITS
SUBJECT
TO
SUBPART
FFF
(
CONTINUED)
TABLE
2.
ANNUAL
FEDERAL
GOVERNMENT
BURDEN
AND
COST
OF
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
OF
THE
FEDERAL
PLAN
FOR
EXISTING
MWC
UNITS
SUBJECT
TO
SUBPART
FFF
ATTACHMENT
4
ECONOMIC
REPORT
OF
THE
PRESIDENT
1996
(
EMPLOYMENT
COST
INDEX)
ATTACHMENT
5
PAPERWORK
REDUCTION
ACT
SUBMISSION
(
OMB
FORM
83­
I)
