SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Municipal
Waste
Combustors
(
40
CFR
part
60,
subparts
Ea
and
Eb)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Municipal
Waste
Combustors
(
40
CFR
part
60,
subparts
Ea
and
Eb)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
subpart
Ea
and
subpart
Eb
were
proposed
on
December
20,
1980,
and
September
20,
1994
(
respectively)
and
promulgated
on
February
11,
1991,
and
December
19,
1995
(
respectively).
Municipal
waste
combustor
(
MWC)
facilities
which
commenced
construction
after
December
20,
1989,
and
on
or
before
September
20,
1994,
or
commenced
modification
or
reconstruction
after
December
20,
1989,
and
on
or
before
June
19,
1996,
are
subject
to
the
regulations
in
40
CFR
part
60,
subpart
Ea.
MWC
facilities
which
commenced
construction
after
September
20,
1994,
or
commenced
modification
or
reconstruction
after
June
19,
1996,
are
subject
to
the
regulations
in
40
CFR
part
60,
subpart
Eb.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
60,
subparts
Ea
and
Eb.

In
general,
all
NSPS
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners
or
operators
of
the
affected
facilities.
They
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
start­
up,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
the
NSPS.

Owners
or
operators
subject
to
the
provisions
of
subpart
Ea
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
Any
owner
or
operator
subject
to
the
provisions
of
subpart
Eb
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
In
addition,
annual
compliance
reports
are
required
for
respondents
(
i.
e.,
sources),
along
with
semiannual
reports
of
excess
emissions,
and
quarterly
reports
for
both
subparts
Ea
and
Eb.

Based
on
our
consultations
with
industry
representatives,
there
is
an
average
of
twelve
sources
that
are
subject
to
subparts
Ea
and
Eb.
There
are
seven
sources
that
are
subject
to
Ea,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years,
since
the
latest
applicability
date
was
June
19,
1996.
It
is
further
assumed
that
there
are
two
affected
facilities
per
plant
per
respondent
(
i.
e.,
the
owner
or
operator
of
the
plant
site).
2
The
remaining
five
sources
are
subject
to
subpart
Eb,
and
it
is
estimated
that
one
additional
source
per
year
will
become
subject
to
the
standard
over
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
two
affected
facilities
per
plant.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
at
$
1,476,293
(
rounded).

All
reports
are
sent
to
the
delegated
state
or
local
authority.
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.

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:

.
.
.
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
addition,
section
114(
a)
states
that
the
Administrator
may
require
any
owner/
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
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
Administrator
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
3
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
organic,
acid
gas,
and
nitrogen
oxide
emissions
from
MWCs
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,
subparts
Ea
and
Eb.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standards
ensure
compliance
with
the
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standards.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standards
at
all
times.
During
the
performance
test
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
compliance
in
place
of
a
continuous
emission
monitor.

The
notifications
required
in
the
standards
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
if
the
pollution
control
devices
are
properly
installed
and
operated
and/
or
leaks
are
being
detected
and
repaired
and
the
standards
are
being
met.
The
performance
test
may
also
be
observed.

The
required
quarterly/
semiannual
reports
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation/
maintenance
procedures
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subparts
Ea
and
Eb.

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
its
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
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.
4
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
(
FR
69
FR
55430)
on
September
14,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
consulted
with
the
preparer
of
the
active
ICR,
and
used
several
different
resources
to
obtain
the
most
recent
data
available
for
municipal
waste
combustors.
We
accessed
the
most
recent
data
(
October
18,
2004)
available
on
the
Air
Facility
System
(
AFS)
databases
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
United
States
Census
Bureau,
and
other
websites
covering
municipal
waste
combustors.
We
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division,
and
Integrated
Waste
Service
Association,
Ms.
Maria
Zanes,
(
202)
467­
6240.

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
is
useful
technique
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequent,
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
the
respondents
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
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
5
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
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
municipal
waste
combustors.
The
United
States
Standard
Industrial
Classification
(
SIC)
codes
for
the
respondents
affected
by
the
standards,
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
codes,
are
listed
below
for
source
category
description.

Standard
(
40
CFR
Part
60,
Subparts
Ea
and
Eb)

Air
and
Water
Resource
and
Solid
Waste
Management
9511
924110
Refuse
Systems
(
hazardous
waste
treatment
and
disposal)
4953
562211
Refuse
Systems
(
material
recovery
facilities)
4953
562920
Refuse
Systems
(
other
nonhazardous
waste
treatment
and
disposal)
4953
562219
Refuse
Systems
(
solid
waste
combustors
and
incinerators)
4953
562213
Refuse
Systems
(
solid
waste
landfills)
4953
562212
4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5(
d)(
2).

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
New
Source
Performance
Standards,
(
NSPS)
for
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb).
6
A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
of
construction/
reconstruction
or
modification
60.7(
a)(
1),
60.59a(
a),
60.59b(
a),
60.59b(
b)
and
60.59b(
c)

Notification
of
preconstruction
plans
and
public
meeting
material
60.59b(
a)

Notification
of
actual
startup
60.7(
a)(
3),
60.59a(
a)
and
60.9b(
c)

Notification
related
to
siting
analysis
60.59b(
a)

Notification
of
initial
performance
tests
60.8(
d)

Notification
of
initial
performance
tests
results
60.8(
a)

Notification
of
demonstration
of
continuous
monitoring
system
60.7(
a)(
5)

Notification
of
physical
or
operational
change
60.7(
a)(
4)

Notification
related
to
opacity
60.7(
a)(
6)
and
60.59b(
c)

Reports
Report
on
initial
performance
test
results
60.8(
a),
60.59a(
c)
and
60.59b(
f)

Report
on
public
meeting
(
notification
and
transcript)
60.59b(
a)(
2)
and
60.59b(
a)(
3)

Report
on
responses
to
public
comment
60.59b(
a)(
4)

Report
on
preliminary
and
final
draft
materials
separation
plans
60.59b(
a)(
1)

Report
on
weights
of
municipal
solid
waste
and
other
fuels
fired
60.59a(
b)(
3)

Report
on
performance
tests/
compliance
report
60.8(
a),
60.59a(
e),
60.59a(
g)
and
60.59b(
g)

Report
excess
emissions
60.59a(
f)
and
60.59b(
h)
7
Reports
Report
on
continuous
emission
monitoring
system
(
CEMS)
demonstration
and
test
data
60.8(
a)
and
60.59b(
f)

Report
of
emission
levels
during
annual
test
(
if
necessary)
60.59b(
d)

Semiannual
report
and
explanation
for
excess
emissions
(
if
necessary)
60.59b(
d)

Semiannual
carbon
report
for
mercury
control
(
if
necessary)
60.59b(
d)

A
source
must
keep
the
following
records:

Recordkeeping
Initial
performance
tests
and
annual
performance
tests
60.59b(
d)

Records
of
periodic
testing
for
fugitive
ash
emissions
60.59b(
d)

Startup,
shutdown,
malfunction
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Occurrence,
duration
of
interruption
in
operation
60.7(
b)

Records
of
sources
with
continuous
monitoring
systems
60.59a(
i)

Results
of
daily
CEMs
drift
tests
and
Appendix
F
accuracy
assessment
60.59b(
d)

Amounts
of
sorbent
used
for
mercury
(
Hg)
control
60.59b(
d)

Persons
reviewing
operating
material
60.59a(
j)
and
60.59b(
d)

Records
are
required
to
be
retained
for
two
years
(
subpart
Ea)
60.59a(
b)

Records
are
required
to
be
retained
for
five
years
(
subpart
Eb)
60.59b(
d)
and
60.59b(
e)

Electronic
Reporting
Currently,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data,
e.
g.,
temperature,
pressures
drop,
leaks
and
spills
of
mercury,
etc.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also,
regulatory
agencies
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
8
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity.

Perform
initial
performance
test,
Reference
Method
19
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.

Perform
site
selection
analysis.

Hold
public
meeting
on
site
analysis
and
material
separation
plan.

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.
9
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.

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.
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
data
for
approximately
125,000
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
40
CFR,
part
60,
subpart
Ea
must
be
retained
by
the
owner
or
operator
for
two
years,
and
for
40
CFR
part
60,
subpart
Eb
the
records
must
be
retained
by
the
owner
or
operator
for
five
years.

The
five­
year
retention
of
records
applies
to
owner
or
operator
of
an
air
curtain
incinerator
with
the
capacity
to
combust
greater
than
250
tons
of
municipal
solid
waste
per
day
that
maintains
records
of
results
of
the
initial
opacity
performance
test
and
subsequent
performance
tests.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
respondents
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
10
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
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb).

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
each
of
the
subparts
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
20,421
(
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
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:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)
11
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
subject
standards
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
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)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

CEMs
for
subpart
Ea
$
60,000
0
$
0
$
8,972
7
$
62,80
4
CEMs
for
subpart
Eb
$
60,000
1
$
60,000
$
8,972
4
$
35,88
8
Total
for
subparts
Ea
and
Eb
­
­
$
60,000
­
­
$
98,69
2
The
total
capital/
startup
costs
for
this
ICR
are
$
60,000.
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
$
99,000
(
rounded).
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
$
159,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
12
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
$
31,069.
Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb),
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
ten
respondents
are
currently
subject
to
the
standard.
It
is
estimated
that
an
additional
one
source
per
year
under
subpart
Eb
will
become
subject
to
the
standard
in
the
next
three
years.
The
average
number
of
respondents
per
year
is,
therefore:
1)
Subpart
Ea
­
7
existing,
and
zero
new;
and
2)
Subpart
Eb
­
4
existing,
and
one
new.
The
average
number
of
existing
respondents
per
year
is
11,
with
one
new
for
a
total
of
12
sources.
This
is
illustrated
below.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)
13
Number
of
Respondents
1
Ea
0
7
0
0
7
2
Ea
0
7
0
0
7
3
Ea
0
7
0
0
7
1Eb1
1
3
0
0
4
2Eb
1
4
0
0
5
3Eb
1
5
0
0
6
Average
1
11
0
0
12
1
Average
number
of
existing
respondents
for
Subpart
Eb
is
four.

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
twelve.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
construction/
reconstruction
for
Ea
0
0
N/
A
0
Notification
of
actual
startup
for
Ea
0
0
N/
A
0
Notification
of
initial
performance
test
for
Ea
0
0
N/
A
0
Notification
of
CMS
demonstration
for
Ea
0
0
N/
A
0
Notification
of
construction/
reconstruction
for
Eb
1
1
N/
A
1
Notification
of
initial
performance
test
for
Eb
1
1
N/
A
1
Compliance
reports
for
Ea
7
1
N/
A
7
14
Total
Annual
Responses
Opacity
reports
for
Ea
(
no
excess
emission)
5.6
1
N/
A
5.6
Opacity
reports
for
Ea
(
excess
emission)
1.4
1
N/
A
1.4
Report
of
daily
weight
of
municipal
solid
waste
(
MSW)
and
fuel
for
Ea
7
4
N/
A
28
Appendix
F
reports
for
Ea
7
4
N/
A
28
Initial
compliance
reports
for
Eb
1
1
N/
A
1
Annual
compliance
reports
for
Eb
4
1
N/
A
4
Semiannual
excess
emission
reports
Eb
4
2
N/
A
8
Appendix
F
quarterly
reports
for
Eb
4
4
N/
A
16
Initial
report
on
site
selection
analysis
for
Eb
1
1
N/
A
1
Public
meetings
and
comment
responses
for
Eb
1
1
N/
A
1
Total
102
The
number
of
Total
Annual
Responses
is
103.
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
$
1,476,293.
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
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb),
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
1,476,293.
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
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb),
attached.

Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
15
information
are
estimated
to
average
198
(
rounded)
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
159,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
are
estimated
to
be
785
labor
hours
at
a
cost
of
$
31,069.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NSPS
for
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb),
attached.

6(
f)
Reasons
for
Change
in
Burden
Even
though
there
is
an
increase
in
the
number
of
sources
from
eight
to
twelve
from
the
most
recently
approved
ICR,
and
an
increase
in
the
hourly
burden
from
11,885
to
20,421,
because
of
the
additional
sources,
there
was
a
decrease
in
the
annual
labor
cost.
This
decrease
in
the
labor
cost
could
partly
be
attributed
to
combining
the
emission
testing
contractor's
hourly
cost
with
the
labor
costs
in
Table
1,
and
properly
accounted
for
the
reporting
requirements
in
the
tables,
e.
g.,
three
line
items
under
write
reports
should
have
been
annual
reporting
instead
of
quarterly
reporting.
We
have
corrected
these
errors
in
the
renewal
package.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
198
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.

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
a
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
16
Docket
ID
Number
OECA­
2004­
0040,
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
NW,
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
Docket
is
(
202)
566­
1752.
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
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0040
and
OMB
Control
Number
2060­
0210
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
17
Table
1:
Annual
Respondent
Burden
and
Cost
­
NSPS
for
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb)

Burden
Item
(
A)
Technical
Personhours
per
Occurrence
(
B)
Number
of
Occurrence
s
Per
Respondent
Per
Year
(
C)
Technical
Person­

Hour
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
a
(
E)
Technical
Person­

Hour
Per
Year
@$
64.60
(
E=
CxD)
b
(
F)
Management
Person­

Hour
Per
Year
@$
95.32
(
Ex0.05)
b
(
G)
Clerical
Person­

Hour
Per
Year
@

$
40.09
(
Ex0.1)
b
(
H)
Total
Labor
Costs
Per
Year
(
I)
Emission
Testing
Contractor
Hours
Per
Occurrence
(
J)
Emission
Testing
Contractor
Hours
Per
Respondent
Per
Year
(
J=
IxB)
(
K)
Contractor
Person­

Hour
Per
Year
(
K=
JxD)
(
L)
Total
Contractor
Costs
Per
Year
(
L=
Kx$
80)
b
1.
Applications
N/
A
N/
A
2.
Survey
and
Studies
N/
A
N/
A
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
2
2
0.1
0.2
$
146.75
1
1
2
$
160.00
B.
Required
activities
Initial
performance
test
for
Eb
24
1
24
1
24
1.2
2.4
$
1,761.00
1,053
i
1,053
1,053
$
84,240.00
Repeat
performance
test
for
Eb
24
1
24
0.2c
4.8
0.24
0.48
$
352.20
1,053
i
1,053
210.6
$
16,848.00
Demonstration/
CEMs
for
Eb
24
1
24
1
24
1.2
2.4
$
1,761.00
470
470
470
$
37,600.00
Repeat
CEM
demonstration
Eb
24
1
24
0.2d
4.8
0.24
0.48
$
352.20
470
470
94
$
7,520.00
Annual
compliance
test
for
Ea
24
1
24
7e
168
8.4
16.8
$
12,327.00
826
j
826
5,782
$
462,560.00
Annual
compliance
test
for
Eb
24
1
24
4
f
96
4.8
9.6
$
7,044.00
1,053
1,053
4,212
$
336,960.00
Appendix
F
audit
for
Ea
(

insitu
125
8
1,000
0
0
0
0
$
0
0
0
0
$
0
Appendix
F
audit
for
Ea
(
extractive)
36
8
288
0
0
0
0
$
0
0
0
0
$
0
C.
Create
Information
Included
in
3B
D.
Gather
information
Included
in
3B
E.
Write
Report
Notification
of
construction/

reconstruction
for
Ea
2
1
2
0
0
0
0
$
0
0
0
0
$
0
Notification
of
actual
startup
­
Ea
2
1
2
0
0
0
0
$
0
0
0
0
$
0
Notification
of
initial
performance
test
­
Ea
2
1
2
0
0
0
0
$
0
0
0
0
$
0
Notification
of
CMS
demonstration
for
Ea
2
1
2
0
0
0
0
$
0
0
0
0
$
0
Notification
of
construction/

reconstruction
for
Eb
2
1
2
1
2
0.1
0.2
$
146.75
0
0
0
$
0
18
Burden
Item
(
A)
Technical
Personhours
per
Occurrence
(
B)
Number
of
Occurrence
s
Per
Respondent
Per
Year
(
C)
Technical
Person­

Hour
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
a
(
E)
Technical
Person­

Hour
Per
Year
@$
64.60
(
E=
CxD)
b
(
F)
Management
Person­

Hour
Per
Year
@$
95.32
(
Ex0.05)
b
(
G)
Clerical
Person­

Hour
Per
Year
@

$
40.09
(
Ex0.1)
b
(
H)
Total
Labor
Costs
Per
Year
(
I)
Emission
Testing
Contractor
Hours
Per
Occurrence
(
J)
Emission
Testing
Contractor
Hours
Per
Respondent
Per
Year
(
J=
IxB)
(
K)
Contractor
Person­

Hour
Per
Year
(
K=
JxD)
(
L)
Total
Contractor
Costs
Per
Year
(
L=
Kx$
80)
b
Notification
of
initial
performance
test
­
Eb
2
1
2
1
2
0.1
0.2
$
146.75
0
0
0
$
0
Annual
compliance
reports
for
Ea
16
1
16
7
112
5.6
11.2
$
8,218.00
0
0
0
$
0
Annual
opacity
reports
of
no
excess
emission
for
Ea
8
1
8
5.6
g
44.8
2.24
4.48
$
3,287.20
0
0
0
$
0
Annual
opacity
report
of
excess
emission
for
Ea
16
1
16
1.4
h
22.4
1.12
2.24
$
1,643.60
0
0
0
$
0
Report
of
daily
weight
of
MSW
and
fuel
for
Ea
34
4
136
7
952
47.6
95.2
$
53,145.40
0
0
0
$
0
Appendix
F
reports
for
Ea
11
4
44
7
308
15.4
30.8
$
21,131.57
0
0
0
$
0
Initial
compliance
report
for
Eb
40
1
40
4
160
8
16
$
11,740.00
0
0
0
$
0
Annual
compliance
report
for
Eb
40
1
40
4
160
8
16
$
11,740.00
0
0
0
$
0
Semiannual
excess
emission
report
Eb
17
2
34
4
136
6.8
13.6
$
9,979.00
0
0
0
$
0
Appendix
F
reports
for
Eb
11
4
44
4
176
8.8
17.6
$
12,914.00
0
0
0
$
0
Initial
site
selection
analysis/
report
for
Eb
270
1
270
4
1,080
54
108
$
79,245.00
0
0
0
$
0
Public
meeting
and
comment
response
for
Eb
140
1
140
4
560
28
56
$
41,090.00
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
Activities
Plan
activities
for
Ea
Included
in
4E
Plan
activities
for
Eb
Included
in
4E
C.
Implement
activities
for
Eb
Included
in
4E
D.
Develop
Record
System
Included
in
19
Burden
Item
(
A)
Technical
Personhours
per
Occurrence
(
B)
Number
of
Occurrence
s
Per
Respondent
Per
Year
(
C)
Technical
Person­

Hour
Per
Respondent
Per
Year
(
C=
A
x
B)
(
D)
Number
of
Respondents
Per
Year
a
(
E)
Technical
Person­

Hour
Per
Year
@$
64.60
(
E=
CxD)
b
(
F)
Management
Person­

Hour
Per
Year
@$
95.32
(
Ex0.05)
b
(
G)
Clerical
Person­

Hour
Per
Year
@

$
40.09
(
Ex0.1)
b
(
H)
Total
Labor
Costs
Per
Year
(
I)
Emission
Testing
Contractor
Hours
Per
Occurrence
(
J)
Emission
Testing
Contractor
Hours
Per
Respondent
Per
Year
(
J=
IxB)
(
K)
Contractor
Person­

Hour
Per
Year
(
K=
JxD)
(
L)
Total
Contractor
Costs
Per
Year
(
L=
Kx$
80)
b
4E
E.
Time
to
enter
information
Record
of
startup/
shutdown/

malfunction
for
Ea
1.5
104
156
7
1,092
54.6
109.2
$
80,125.50
0
0
0
$
0
Record
emission
measurements
1.5
104
156
7
1,092
54.6
109.2
$
80,125.50
0
0
0
$
0
Record
of
employee
review
of
operation
for
Ea
4
2
8
7
56
2.8
5.6
$
4,109.00
0
0
0
$
0
Record
of
startup/
shutdown/

malfunction
for
Eb
1.5
94
141
4
564
28.2
56.4
$
41,383.50
0
0
0
$
0
Record
of
emission
rates,
and
computation
tests
for
Eb
1.5
94
141
4
564
28.2
56.4
$
41,383.50
0
0
0
$
0
Record
of
employee
review
of
operation
for
Eb
4
2
8
4
32
1.6
3.2
$
2,348.00
0
0
0
$
0
Record
of
amount
of
sorbent
for
Hg
control
for
Eb
0.1
94
9.4
4
37.6
1.88
3.76
$
2,758.90
0
0
0
$
0
F.
Time
to
train
personnel
Included
in
4E
G.
Time
for
audits
Included
in
3E
SUBTOTAL
LABOR
BURDEN
AND
COST
7,476.4
373.82
747.64
$
530,405.32
11,823.6
$
945,888.00
Labor
Hours
(
E+
F+
G)
8,597.86
Labor
Cost
$
530,405.32
TOTAL
LABOR
BURDEN
&
COST
Contractor
Labor
Hours
11,823.6
Contractor
Labor
Cost
$
945,888.00
Total
Hours
(
rounded)
20,421
Total
Cost
(
rounded)
$
1,476,293
ASSUMPTIONS:

a
We
have
estimated
that
an
average
of
12
sources
are
subject
to
subparts
Ea
and
Eb.
Seven
of
these
sources
are
currently
subject
to
subpart
Ea,
with
no
additional
sources
becoming
subject
to
the
regulation
in
the
next
three
years.
The
remaining
five
sources
are
subject
to
subpart
Eb
(
4
existing
and
1
new).
We
have
assumed
that
one
additional
source
per
year
will
become
subject
to
the
standard
over
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
two
affected
facilities
per
plant
per
respondent.
20
b
Assume
that
all
tasks
are
to
be
performed
by
managerial,
technical
and
clerical
personnel.
This
ICR
uses
the
following
labor
rates:
$
95.32
for
Managerial
labor,
$
64.60
for
Technical
labor
and
$
40.09
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor
Bureau
of
Labor
Statistics,
December
2003,
"
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
have
also
included
contractors'
rate
at
$
80.00
per
hour.

c
It
is
estimated
that
20
percent
of
respondents
will
repeat
performance
test
for
Eb.

d
It
is
assumed
that
20
percent
of
the
respondents
will
repeat
CEM
demonstration
activity
for
Eb.

e
Assume
that
seven
respondents
for
subpart
Ea
will
have
to
complete
an
annual
compliance
test.

f
Assume
that
four
respondents
for
subpart
Eb
will
have
to
complete
an
annual
compliance
test.

g
It
is
assumed
that
80
percent
of
respondents
will
file
an
opacity
report
of
no
excess
emission
for
Ea.

h
It
is
assumed
that
20
percent
of
respondents
will
file
an
opacity
report
of
excess
emission
for
Ea.

i
Assumed
that
it
will
take
an
emission
testing
contractor
1,053
hours
to
perform
both
initial
performance
test
and
repeat
performance
test
for
subpart
Eb.

j
Assumed
that
it
will
take
an
emission
testing
contractor
826
hours
to
complete
an
annual
compliance
test
for
Eb.
21
TABLE
2:
Average
Annual
EPA
Burden
­
NSPS
for
Municipal
Waste
Combustors
(
40
CFR
Part
60,
Subparts
Ea
and
Eb)

BURDEN
ITEMS
(
A)
Technical
Person
Hours
Per
Occurrences
(
B)
Number
of
Occurrence
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
Cost
Per
Year
a
Activity
Initial
performance
tests
for
Ea
180
1
180
0
0
0
0
$
0
Review
report
of
initial
performance
test
for
Ea
24
1
24
0
0
0
0
$
0
Repeat
performance
test
for
Ea
12
1
12
0
0
0
0
$
0
Repeat
performance
test
for
Eb
12
1
12
0.2c
2.4
0.12
0.24
$
109.17
Report
Review
for
Ea
­
notification
of
construction
2
1
2
0
0
0
0
$
0
­
notification
of
actual
startup
2
1
2
0
0
0
0
$
0
­
notification
of
initial
test
2
1
2
0
0
0
0
$
0
­
notification
of
CMS
demonstration
12
1
12
0
0
0
0
$
0
Review
of
CEMS
demonstration
for
Ea
96
1
96
0
0
0
0
$
0
Report
Review
for
Eb
­
notification
of
construction
2
1
2
1b
2
0.1
0.2
$
90.98
­
notification
of
actual
startup
2
1
2
1b
2
0.1
0.2
$
90.98
­
notification
of
initial
performance
test
8
1
8
1b
8
0.4
0.8
$
363.90
­
notification
of
CEMS
demonstration
5
1
5
1b
5
0.25
0.5
$
227.45
Review
CEMS
demonstration
for
Eb
40
1
40
1b
40
2
4
$
1,819.52
Review
excess
emission
reports
for
Ea
­
no
excess
emission
report
8
1
8
5.6e
44.8
2.24
4.48
$
2,037.87
­
excess
emission
report
2
1
2
1.4
f
2.8
0.14
0.28
$
127.67
Review
semiannual
excess
emission
reports
for
Eb
12
2
24
4g
96
4.8
9.6
$
4,366.85
Review
quarterly
appendix
F
reports
for
Ea
0.5
4
2
7h
14
0.7
1.4
$
636.83
Review
quarterly
compliance
report
for
Ea
8
4
32
7h
224
11.2
22.4
$
10,189.31
Review
annual
compliance
reports
for
Eb
5
1
5
4i
20
1
2
$
909.76
Review
annual
compliance
tests
for
Ea
18j
1
18
7
126
6.3
12.6
$
5,731.49
Review
siting
requirements
study
for
Eb
24
1
24
4
k
96
4.8
9.6
$
4,366.85
22
Subtotal
683
34.15
68.3
$
31,068.63
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
785
$
31,069
Assumptions:

a
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
54.66
for
Managerial
(
GS­
13,
Step
5,
$
34.16
x
1.6),
$
40.56
for
Technical
(
GS­
12,
Step
1,
$
25.35
x
1.6)
and
$
21.95
Clerical
(
GS­
6,
Step
3,
$
13.72
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

b
It
is
estimated
that
one
new
source
per
year
over
the
next
three
years
would
be
subject
to
subpart
Eb.

c
It
is
estimated
that
20
percent
of
respondents
are
required
to
perform
retest
preparations
for
subpart
Eb.

d
It
is
assumed
that
20
percent
of
respondents
will
have
to
perform
retest
observance
for
Eb.

e
It
is
assumed
that
80
percent
of
respondents
will
review
reports
for
no
excess
emission
for
subpart
Ea.

f
It
is
also
assumed
that
20
percent
of
respondents
will
review
reports
for
excess
emission
for
subpart
Ea.

g
Assumed
that
four
respondents
that
are
subject
to
subpart
Eb
will
review
semiannual
excess
emission
reports.

h
It
is
assumed
that
all
seven
respondents
that
are
currently
subject
to
subpart
Ea
will
have
to
review
quarterly
reports.

i
Assumed
that
all
four
respondents
that
are
subject
to
subpart
Eb
will
have
to
review
annual
compliance
reports.

j
We
have
assumed
that
it
will
take
18
hours
to
review
the
annual
compliance
test
for
Ea.

k
All
of
the
four
respondents
that
are
subject
to
subpart
Eb
will
have
to
review
the
siting
requirement's
study.
