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 



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:



. . . 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).



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 

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 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,

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





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:

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
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.



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 (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%)

(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 Respondent	

(B)

Number of Initial Respondents  	

(C)

Total Capital/Startup Cost, (AxB)	

(D) 

Annual O&M Costs for One Respondent 	

(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 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.

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 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) 

















	

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             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	

	

	

	

	

	

 	

	

 	

	

 	





	

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.

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.











































































	

 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).

 See Section 6(d) for calculation.

 We have assumed that the annual O$M cost are $211 per year.

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.

 PAGE  17 

