SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

State and Federal Emission Guidelines for Hospital/Medical/Infectious
Waste Incinerators 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

State and Federal Emission Guidelines for Hospital/Medical/Infectious
Waste Incinerators (40 CFR part 60, subpart Ce and 40 CFR part 62,
subpart HHH) (Renewal)

1(b)  Short Characterization/Abstract

This supporting statement addresses information collection activities
imposed by the Emission Guidelines for Hospital/Medical/Infectious Waste
Incinerators (Emission Guidelines), 40 CFR part 60, subpart Ce and 40
CFR part 62, subpart HHH.  Subpart Ce, promulgated on September 15,
1997, requires states or tribes to develop plans to implement the
Emission Guidelines.  If approvable state or tribal plans were not
developed, EPA was required to develop a Federal plan to implement the
Emission Guidelines in such states or tribes.  The Federal plan, subpart
HHH was promulgated on September 14, 2000.  For the purpose of this
Information Collection Request (ICR), subparts Ce and HHH will be
referred to as "the Emission Guidelines."  States and tribes may choose
to impose more stringent requirements.  However, the burden estimates
provided in this ICR assume that the state and tribal plans mirror the
Emission Guidelines.

The Emission Guidelines require initial notifications, performance
tests, and annual and semiannual reporting.  Owners or operators are
also required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  These notifications reports, and records are essential in
determining compliance.  Any owner or operator subject to the provisions
of this part shall 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.  All reports are sent to the state or
tribal authority with an approved plan.  In the event that there is no
such approved plan, the reports are sent directly to the EPA regional
office.

The reporting and recordkeeping requirements differ for
Hospital/Medical/Infectious Waste Incinerators (HMIWI) burning hospital
waste and/or medical/infectious waste; for combustors co-firing hospital
waste and/or medical/infectious waste with other fuels; and for
incinerators burning only pathological, low-level radioactive, and/or
chemotherapeutic waste.  For this reason, reporting and recordkeeping
requirements are described separately for each of these three facility
types.  This information is being collected to assure compliance with 40
CFR part 60, subpart Ce and 40 CFR part 63, subpart HHH.

Based on an EPA Office of Air Quality Planning and Standards (OAQPS)
facility and emissions indexing effort for HMIWI, we have determined
that there are 72 existing HMIWI located at 66 different facilities. 
This standard regulates only existing sources, therefore, no new
respondent will become subject to the regulation over the next three
years.

Terms of Clearance

OMB requested that when EPA resubmits the ICR for renewal, the Agency
should re-evaluate its assumption that no new sources would become
subject to the reporting and recordkeeping requirements.  In addition,
the agency should include a more detailed description of the estimates
used to derive the annual operation and maintenance costs.

In response to OMB’s request, we reviewed the analysis conducted as
part of the previous ICR that found that no new sources would become
subject to the standards.  The Emission Guidelines only apply to
existing sources.  New sources are subject to the Standards of
Performance for Hospital/Medical/Infectious Waste Incinerators (40 CFR
part 60, subpart Ce). Therefore, no new sources are subject to this
standard.  A more detailed description of the estimates used to derive
the annual operation and maintenance costs is provided in section 6(b).

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; . . . .

In the Administrator's judgment, particulate matter (PM), carbon
monoxide (CO), dioxins/furans (D/F), hydrogen chloride (HCl), sulfur
dioxide (SO2), nitrogen oxides (NOx), lead (Pb), cadmium (Cd), and
mercury (Hg) emissions from hospital, medical, or infectious waste
incinerators contribute to air pollution that may reasonably be
anticipated to endanger public health or welfare.  Therefore, the state
and federal emission guidelines were promulgated for this source
category at 40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH.

2(b)  Practical Utility/Users of the Data

	The control of emissions of PM, CO, D/F, HCl, SO2, NOx, Pb, Cd, and Hg
from HMIWIs requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of these pollutants from HMIWIs are the result of operation of
the facilities affected by the Emission Guidelines.  The subject
standards are achieved by the capture and/or reduction of these
pollutants using good combustion practices and appropriate filter and
scrubber technology.

	The notifications required in the applicable regulations are used to
inform the Designated Agency that a source is 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 the regulations are being met. 
Performance test reports are needed as these provide a record of a
source’s initial capability to comply with the emission standard, and
serve as a record of the operating conditions under which compliance was
achieved.  Operating conditions monitored include the highest maximum
and lowest minimum operating parameters and exceedances of emission
rates or operating parameters.  Annual and semiannual reports are used
for problem identification, as a check on source operation and
maintenance, and for compliance determinations.  The information
generated by the monitoring, recordkeeping, and reporting requirements
described in this ICR is used by the Agency to ensure that facilities
affected by the Emission Guidelines continue to operate the control
equipment and achieve compliance with the regulation.  Adequate
monitoring, recordkeeping, and reporting are necessary to ensure
compliance with the applicable regulations, as required by the Emission
Guidelines.  The information collected from recordkeeping and reporting
requirements is also used for targeting inspections, and is of
sufficient quality to be used as evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60 subpart Ce, and 40 CFR part 62, subpart HHH.

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 local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

	The Office of Air Quality Planning and Standards (OAQPS) is currently
in the process of reviewing the Emission Guidelines as required by
Section 129(a(5) of the Clean Air Act.  As part of the review, OAQPS, in
consultation with industry, developed a HWIWI facility and emissions
index for sources subject to these standards.  As a result, we were able
to rely on the information from the facility and emissions index (dated
March 2006) to obtain recent information on the universe of sources
subject to the standard in order to estimate the burden of the Emission
Guidelines on industry.

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 less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 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 records retention requirement is consistent
the Part 70 permit program and the five year statute of limitations on
which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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 (CBI) (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

The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are
owners or operators of hospital, medical, or infectious waste
incinerators.  The United States Standard Industrial Classification
(SIC) codes and corresponding North American Industry Classification
System (NAICS) classifications for the respondents are listed in the
table below.

40 CFR part 60, subpart Ce Source Categories	SIC Codes	NAICS Codes

Hospitals 	806	622110

Refuse Systems	4953	562213

Commercial Physical and Biological Research	8731	541740

Nursing and Personal Care Facilities	805	623110 and 623111

Veterinary Services	074	542940

	

	4(b)  Information Requested

(i)  Data Items

	In this ICR, all the data that is recorded or reported is required by
State and Federal Emission Guidelines for Hospital/Medical/Infectious
Waste Incinerators (40 CFR part 60, subpart Ce and 40 CFR part 62,
subpart HHH).

A source must make the following reports:

State and Federal Emission Guidelines for Hospital/Medical/Infectious
Waste Incinerators (40 CFR part 60, subpart Ce and 40 CFR part 62,
subpart HHH).	Regulation Reference

Installation of CMS	60.37e, 60.56c, 60.57c, 62.14454

Initial and repeat performance specification tests for CMS	60.37e,
60.56c, 60.57c, 62.14454(f)

Initial equipment inspection (small rural HMIWI)	60.37e(b), 60.56c,
60.57c, 62.14440

Increments of progress for HMIWI that will comply with regulation
60.39e(c)

Request for extension to shut down late	60.39e(d)

Waste management plan	60.35e(a), 60.55c(c), 60.58c(c), 62.14430

Notification of HMIWI capacity	60.58c(a)

Notification of initial CMS demonstration	60.38e(a), 60.7

Report of initial CMS demonstration	60.38e(a), 60.7(c)

Notification of exemption claim for combustors burning pathological,
low-level radioactive, and/or chemotherapeutic waste	60.32e(b)

Annual report containing information from annual equipment inspection,
required maintenance, and repairs not completed during established time
frame	60.38e(b)

Notification of exemption claim for co-fired combustors	60.32e(c)

Notification of relative weight of hospital waste, medical/infectious
waste, and other fuels and/or wastes to be combusted at co-fired
combustor	60.32e(c)

Notification of initial performance tests (PM, CO, fugitive emissions,
stack opacity, dioxins/furans, HCl, Cd, Pb, Hg)	60.38e(a), 60.8(d)

Report on initial performance test data (PM, CO, fugitive emissions,
stack opacity, dioxins/furans, HCl, Cd, Pb, Hg)	60.38e(a), 60.58c(c),
60.8(a), 62.14463(a)

Values for site-specific operating parameters	60.38e(a), 60.58c(c),
62.14463(b)

Annual report of values for site-specific operating parameters
60.38e(a), 60.58c(d), 62.14463(f)

Annual report of the highest maximum and lowest minimum operating
parameters (covering the last two years)	60.38e(a), 60.58c(d),
62.14463(d)

Annual report of emissions or operating parameter exceedances,
malfunctions, and periods for which data on emissions/operating
parameters were not obtained (covering the last two years)	60.38e(a),
60.58c(d), 60.7(c), 62.14463(g)

Annual report containing results of annual performance test	60.38e(b),
60.58c(d), 62.14464(b)

If no excess emissions, malfunctions, or operating parameter
exceedances, annual report stating so	60.38e(a) 60.58c(d), 62.14463(i)

Any use of the bypass stack, duration, reason for malfunction, and
corrective action taken 	60.38e(a) 60.58c(d), 62.14463(j)

Semiannual report of emissions or operating parameter exceedances,
malfunctions, and periods for which data on emissions/operating
parameters were not obtained	60.38e(a) 60.58c(e), 60.7(c), 60.7(d),
62.14464(c)

Annual update of operating information	60.34(e), 60.53c(i), 62.14423(c)

Annual review of operating information with each operator	60.34(e),
60.53c(h), 62.14425(a)



A source must keep the following records:

State and Federal Emission Guidelines for Hospital/Medical/Infectious
Waste Incinerators (40 CFR part 60, subpart Ce and 40 CFR part 62,
Subpart HHH)	Regulation Reference

5-year retention of records, related to emissions	60.38e(a), 60.58c(b),
60.58c(f), 62.14461

Records of startup, shutdown, or malfunction	60.38e(a), 60.57c, 60.7(b),
62.14460(d)

Records of initial performance test	60.37e, 60.57c, 62.14460(a)

Records of CMS operation and maintenance	60.38e(a), 60.57c, 60.7(f),
62.14460(a)

Records of annual equipment inspections, required maintenance, and
repairs not completed during established timeframe	60.38e(b),
62.14460(a)

Records on a quarterly basis of periods of time when only pathological,
low-level radioactive, and/or chemotherapeutical waste is burned
60.32e(b), 62.14400

Records on quarterly basis of weight of hospital waste and
medical/infectious waste combusted, and weight of all other fuels and
waste combusted at co-fired combustors	60.32e(c), 62.14400

Records for which data on emissions/operating parameters were not
obtained	60.38e(a), 60.58c(b), 60.8(f), 62.14460(c)

Records related to malfunctions	60.38e(a), 60.58c(b), 60.8(f),
62.14460(d)

Records of emissions or operating parameter exceedances	60.38e(a),
60.58c(b), 60.8(f), 62.14460(e)

Records of initial, annual, and any subsequent performance tests
60.38e(a), 60.58c(b), 60.8(f), 62.14460(f)

Records of persons completing reviews of HMIWI operating manual (initial
and annual)	60.38e(a), 60.58c(b), 62.14460(g)

Records of operators completing operator training course and
qualification requirements	60.38e(a), 60.58c(b), 62.14460(h)

Records of operators who have met the qualification requirements
60.38e(a), 60.58c(b), 62.14460(i)

Records of calibration of any monitoring devices	60.38e(a), 60.58c(b),
62.14460(j)

Records of emissions, process, and control device operating parameters
60.38e(a), 60.58c(b), 60.8(f), 62.14460(a)



Electronic Reporting

	Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a 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
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 or continuous emission
monitoring systems for continuously measuring and recording the
emissions of pollutants from an affected facility

Perform initial performance test and repeat performance tests if
necessary.  Use applicable reference test method.

Write the notifications and reports listed above

Develop site-specific operating parameters

Develop waste management plan

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 could 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.  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 this regulation must be retained by the
owner/operator for five years.

5(c)  Small Entity Flexibility

	The majority of affected facilities are not small entities or small
businesses.  However, when promulgated, the Emission Guidelines were
designed to address the needs of small entities and small businesses.

	The Emission Guidelines standards and reporting requirements for
co-fired combustors and for incinerators burning only pathological,
low-level radioactive, and/or chemotherapeutical waste are less
restrictive than those for HMIWIs.  For example, co-fired combustors and
incinerators burning only pathological, low-level radioactive, and/or
chemotherapeutical waste are not required to conduct performance tests. 
The Emission Guidelines standards and reporting requirements for small
rural HMIWI are less restrictive than those for other HMIWI.  For
example, small rural HMIWI are not required to conduct an initial
performance test for HCl and are required to conduct annual performance
tests for opacity only.  Monitoring requirements for small rural HMIWI
are also less restrictive.  Additionally, small non-rural, medium, and
large HMIWI are allowed to skip annual tests and reports for PM, CO, and
HCl for 2-year periods if they have demonstrated compliance for three
annual tests in a row.  All of these provisions will reduce the burden
on HMIWI.  The other reporting requirements have been critically
reviewed and determined to be necessary for ascertaining compliance with
the standards.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost of
the Reporting and Recordkeeping Requirements for State and Federal
Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators
(40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH).

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 subparts included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

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

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 69,067
hours (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 part 60 and 62 regulations, 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	$97.46   ($46.41 + 110%)

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, Table 2. Civilian Workers, 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 type of industry costs associated with the information collection
activities in the subject standard(s) 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 costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor(s) and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Use the following table and subsequent paragraphs only if you have
capital/startup and O&M costs.

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondentsa	(D)

Total Capital/Startup 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)

Temperature, pressure, flow rate, charge rate, voltage, and pH monitors
n/a	0	0	$1,800	72	$129,600

a Based on the data collected by OAQPS as part of the facility and
emissions index (March 2006), the average HMIWI operates approximately 6
continuous monitoring devices.  The average cost per monitoring device
is $300 per year.  Therefore, the estimate O&M cost per respondent is
estimated to be $1,800.

As noted in Section 1(b), no new sources are subject to this subpart to
the Emission Guidelines.  Therefore, there are no capital/startup costs
for this ICR.  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
$130,000 (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 costs to industry over the next three years of
the ICR is estimated to be $130,000 (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 $137,181.  This cost is based on the average hourly
labor rate as follows:

	Managerial	$57.20  (GS-13, Step 5, $35.75 x 1.6)

	Technical	$42.45  (GS-12, Step 1, $26.53 x 1.6)

	Clerical	$22.96  (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) 2006
General Schedule which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2:  Average Annual EPA
Resource Requirement for State and Federal Emission Guidelines for
Hospital/Medical/Infectious Waste Incinerators (40 CFR part 60, subpart
Ce and 40 CFR part 62, subpart HHH), attached.

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three
years, approximately 72 existing respondents will be subject to the
standard.  It is estimated that no new respondents per year will become
subject.  The overall average number of respondents, as shown in the
table below is 72 per year.  The number of respondents is calculated
using the following table that 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)

1	0	72	0	0	72

2	0	72	0	0	72

3	0	72	0	0	72

Average



	72



As shown above, the average Number of Respondents over the three year
period of this ICR is 72.  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

Annual Reports	72	1	0	72

Semi-Annual Reports of Emissions/Parameter Exceedances	72	2	0	144



	Total	216



The number of Total Annual Responses is 216.  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 $5,575,702.  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 of the Reporting and
Recordkeeping Requirements for State and Federal Emission Guidelines for
Hospital/Medical/Infectious Waste Incinerators (40 CFR part 60, subpart
Ce and 40 CFR part 62, subpart HHH), attached.

The total annual capital/startup and O&M costs to the regulated entities
are $130,000 (Rounded).  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.

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 the attached Tables 1 and 2,
respectively.

(i) Respondent Tally

The Total Hours Requested is estimated to be 69,067.  This estimate is
shown on the OMB 83-I form in block 13(c).  The total annual labor costs
associated with the hours requested are $5,575,702.  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 of
the Reporting and Recordkeeping Requirements for State and Federal
Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators
(40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 320 hours per
response.

The total annual capital/startup and O&M costs to the regulated entities
are estimated to be $130,000 (Rounded).  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 is
estimated to be 3,314 labor hours at a cost of $137,181.  See Table 2:
Average Annual EPA Resource Requirement for State and Federal Emission
Guidelines for Hospital/Medical/Infectious Waste Incinerators (40 CFR
part 60, subpart Ce and 40 CFR part 62, subpart HHH), attached.

6(f)  Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to an
adjustment.  The decrease in burden from the most recently approved ICR
is due to a decrease in the number of sources.  Our estimate is based on
a facility and emissions index of HMIWI sources developed by OAQPS.  The
data in the index was collected directly from industry and updated March
2006.

The previous estimate of 189 respondents was derived from approximated
state agency data.  In addition, the standard applies only to facilities
which commenced construction on or before June 20, 1996.  As described
above, the current estimate of 72 sources represents a source-by-source
count and takes into account those sources which have shutdown. 
Therefore, we have adjusted the number of respondents from 189 to 72. 
The decrease in cost from $295,407 to $130,000 is due to the decrease in
the number of affected sources.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 320 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
EPA-HQ-OECA-2005-0036, which is available for online viewing at 
www.regulations.gov,  or in person 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, DC  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)566-1752.  An electronic version of the
public docket is available through EPA Dockets www.regulations.gov. 
This site can be used 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.  You can also send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. 
Please include the EPA Docket Number:  EPA-HQ OECA-2005-0036, and OMB
Control Number 2060-0422 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 Respondent Burden and Cost of the Reporting and
Recordkeeping Requirements for State and Federal Emission Guidelines for
Hospital/Medical/Infectious Waste Incinerators (40 CFR part 60, subpart
Ce and 40 CFR part 62, subpart HHH)























(C)

(E)	(F)	(G)









	Person-

Technical	Management	Admin	(H)	(I)





	(A)	(B)	hours per

person-	person-	person-	Total	Total





	Person-	Number of	respondent	(D)	hours	hours	hours	hours per	Labor





	hours per	occurrences	per year	Respondents	per year	per year	per year
year 	Cost,

	Burden item	occurrence	per year	(D = A x C)	per year	(F = D x E)	(G = F
x 0.05)	(H = F x 0.1)	(I = E+F+G)	$

	 1.	Applications	N/A  









	 2.	Surveys and studies	N/A  









	 3.	Reporting requirements (HMIWI)











	A.	Read and understand rule requirements	40 	1	40 	0 	0 	0 	0 	0 	$0



B.	Required activities













--Installation of CMS	15 	1	15 	0 	0 	0 	0 	0 	$0



	--Perf. spec. tests (certif.) for CMS	8 	1	8 	0 	0 	0 	0 	0 	$0



	--Repeat perf. spec. tests (certif.) for CMS	8 	1	8 	0 	0 	0 	0 	0 	$0



	--Initial equipment inspection (small rural HMIWI)	8 	1	8 	0 	0 	0 	0 
0 	$0



	--Annual update of operating information	20	1	20 	72 	1,440 	72.0	144.0
1,656.0	$133,686.72



	--Review operating information with each operator	8	2	16 	72 	1,152 
57.6	115.2	1,324.8	$106,949.38



	--Annual equipment inspection (small rural HMIWI)	8 	1	8 	6 	48 	2.4
4.8	55.2	$4,456.22



C.	Create information	Incl. in 3.B.

 









	--Development of operating information	160	1	160 	0 	0 	0 	0 	0 	$0



D.	Gather existing information	Incl. in 3.B.

 









E.	Write report (HMIWI)













--Increments of progress for HMIWI that will comply













	-Control plan	24 	1	24 	0 	0 	0 	0 	0 	$0





-Notificaton of construction contracts	2 	1	2 	0 	0 	0 	0 	0 	$0





-Notification of construction commencement	2 	1	2 	0 	0 	0 	0 	0 	$0





-Notification of construction completion	2 	1	2 	0 	0 	0 	0 	0 	$0





-Notification of control plan completion	2 	1	2 	0 	0 	0 	0 	0 	$0



	--Request for extension to shut down late	12 	1	12 	0 	0 	0 	0 	0 	$0



	--Notification of initial performance test	2 	1	2 	0 	0 	0 	0 	0 	$0



	--Notification of initial CMS demonstration	2 	1	2 	0 	0 	0 	0 	0 	$0



	--Waste management plan	160	1	160 	0 	0 	0 	0 	0 	$0



	--Report of initial performance test for PM, CO, Hg,	560 	1	560 	0 	0 
0 	0 	0 	$0



	dioxins/furans, & stack opacity (small rural HMIWI)

	 





 



	--Report of initial performance test for PM, CO, HCl,	640 	1	640 	0 	0 
0 	0 	0 	$0



	dioxins/furans, metals, & stack opacity













 (small non-rural, medium, and large HMIWI)













--Report of initial CMS demonstration	Incl. in 3.B.











	--Annual report (small non-rural, medium, and large HMIWI)













--CMS operating parameters	15 	1	15 	66 	990 	49.5	99.0	1,138.5
$91,909.62





--Emissions/parameter exceedances and periods	64 	1	64 	13.2 	844.8 
42.2	84.5	971.5	$78,429.54





when emission/parameter data not obtained













	--Report of annual performance test	280 	1	280 	53 	14,840 	742.0
1,484.0	17,066.0	$1,377,715.92





--Report of no exceedances	32 	1	32 	53 	1,696 	84.8	169.6	1,950.4
$157,453.25



	--Annual report (small rural HMIWI)













	--CMS operating parameters 	15 	1	15 	6 	90 	4.5	9.0	103.5	$8,355.42





--Emissions/parameter exceedances and periods	16 	1	16 	1.2 	19.2 	1.0
1.9	22.1	$1,782.49





when emission/parameter data not obtained













	--Report of annual performance test	20 	1	20 	6 	120 	6.0	12.0	138.0
$11,140.56





--Report of no exceedances	8 	1	8 	4.8 	38.4 	1.9	3.8	44.2	$3,564.98





--Report of annual equipment inspection	Incl. in 3.B.









 

	--Semiannual report of emissions/parameter exceedances	32 	2	64 	13.2 
845 	42.2	84.5	971.5	$78,429.54



	and periods when emission/parameter data not obtained











	(small non-rural, medium, and large HMIWI)













--Semiannual report of emissions/parameter exceedances	8 	2	16 	1.2 
19.2 	1.0	1.9	22.1	$1,782.49



	and periods when emission/parameter data not obtained











	(small rural HMIWI)

















(C)

(E)	(F)	(G)









	Person-

Technical	Management	Admin	(H)	(I)





	(A)	(B)	hours per

person-	person-	person-	Total	Total





	Person-	Number of	respondent	(D)	hours	hours	hours	hours per	Labor





	hours per	occurrences	per year	Respondents	per year	per year	per year
year 	Cost,

	Burden item	occurrence	per year	(D = A x C)	per year	(F = D x E)	(G = F
x 0.05)	(H = F x 0.1)	(I = E+F+G)	$

	 4.	Reporting requirements (co-fired combustors and pathological/











low-level radioactive/chemotherapeutic waste combustors)











A.	Read instructions	N/A











B.	Required activities	N/A











C.	Create information	N/A











D.	Gather existing information	N/A











E.	Write report













--Notification of exemption claim	2 	1	2 	0 	0 	0 	0 	0 	$0



	--Notification of relative amounts of hospital waste,	2 	1	2 	0 	0 	0 
0 	0 	$0



	medical/infectious waste, and other fuels and wastes













to be combusted (co-fired combustors only)











 5.	Recordkeeping requirements (HMIWI)











	A.	Read instructions	N/A  











B.	Plan activities	N/A  











C.	Implement activities	N/A  











D.	Develop record system	N/A  











E.	Time to enter information













--Records of startup, shutdown, or malfunction	1.5	52	78.0	72	5,616 
280.8	561.6	6,458.4	$521,378.21



	--Records of persons reviewing operating information	2 	2	4 	72 	288 
14.4	28.8	331.2	$26,737.34



	--Records of operators completing training requirements	2 	1	2 	0 	0 
0.0	0.0	0.0	$0



	--Records of operators that have been qualified	2 	1	2 	0 	0 	0.0	0.0
0.0	$0



	--Records of initial performance test	Incl. in 3.E.











	--Records of process and control device operating	1.5	52	78.0	66.0
5,148.0	257.4	514.8	5,920.2	$477,930.02



	parameters (small non-rural, medium, and large HMIWI)

	 









--Records of CMS operation and maintenance	1.5	250	375.0	66.0	24,750.0
1,237.5	2,475.0	28,462.5	$2,297,740.50



	 (small non-rural, medium, and large HMIWI)













--Records of emissions/parameter exceedances and	1.5	52	78.0	13.2
1,029.6	51.5	103.0	1,184.0	$95,586.00



	periods when emission/parameter data not obtained













 (small non-rural, medium, and large HMIWI)













--Records of process and control device	0.5	52	26.0	6.0	156.0	7.8	15.6
179.4	$14,482.73



	operating parameters (small rural HMIWI)













--Records of CMS operation and maintenance	0.5	250	125.0	6.0	750.0	37.5
75.0	862.5	$69,628.50



	 (small rural HMIWI)













--Records of emissions/parameter exceedances and	0.5	52	26.0	1.2	31.2
1.6	3.1	35.9	$2,896.55



	periods when emission/parameter data not obtained













 (small rural HMIWI)













--Records of annual and subsequent compliance tests	Incl. in 3.E.











	--Records of annual equipment inspection	Incl. in 3.B.











G.	Time to train personnel	40 	1	40 	0 	0 	0 	0 	0 	$0



H.	Time for audits	N/A  









	 6.	Recordkeeping requirements (co-fired and pathological/











	low-level radioactive/chemotherapeutic combustors)











	A.	Read instructions	N/A  











B.	Plan activities	N/A  











C.	Implement activities	N/A  











D.	Develop record system	N/A  











E.	Time to enter information













--Quarterly records of periods when only pathological,	2 	4	8	13.4	107.2
5.4	10.7	123.3	$9,952.23



	low-level radioactive, chemotherapeutic waste burned













--Quarterly records of weight of hospital waste and	2 	4	8	5.0	40.0	2.0
4.0	46.0	$3,713.52



	medical/infectious waste combusted, and weight of













all other fuels and wastes combusted (co-fired only)











	F.	Time to train personnel	N/A  











G.	Time for audits	N/A  









	TOTAL RESPONDENT BURDEN AND COST NATIONWIDE:



60,058 	3,003 	6,006 	69,067 	$5,575,702















































	ASSUMPTIONS











	We estimate that there are 72 existing HMIWI, including approximately 6
small rural HMIWI, 2 small non-rural HMIWI, 20 medium HMIWI, and 44
large HMIWI.



	A zero value for number of respondents indicates that burden was
incurred prior to the time period covered by this supporting statement.





Assume 20 percent of the 72 existing HMIWI (13.4) burn pathological,
low-level radioactive, and chemotherapeutic waste; and assume 7 percent
of existing HMIWI (5.0) are co-fired combustors.



Costs are based on the following hourly rates:  technical at $83.71,
management at $97.46, and administrative at $42.55.





	Assume 8 hour for performance test of CMS.











	Assume 8 hours for equipment inspection.











	Assume 20 hours to update the operating information each year.











Assume 8 hours to review the operating information with each operator.









	Assume 2 operators per facility.  Also assume there is no operator
turnover at the affected facilities.







	Assume 160 hours for each facility to develop the operating
information.









	Assume that 5 percent of HMIWI that shut down will request an extension
to shut down after the first compliance date (3 years after promulgation
of the Emission Guidelines).



Assume 160 hours for each facility to develop the waste management plan.









	Assume 40 hours for each facility to review the report of the initial
performance test.









Assume 15 hours for incorporating operating hours into annual report.









	Assume 16 and 8 person-hours per report per pollutant to report
monitoring exceedances and no excess emissions, respectively.  





	For small rural HMIWI, assume 8 hours to review report of annual stack
opacity compliance test.  







	For small non-rural, medium, and large HMIWI assume 40 hours to review
report of annual stack opacity compliance test.





	Assume 20 percent of respondents can take advantage of annual skip
testing (forgo annual testing because passed previous 3 tests).





Assume 20 percent of respondents report monitoring exceedances.











For small rural HMIWI, assume 0.5 hours per week to record process and
control device operating parameters and to record any exceedances of
these parameters.



For small non-rural, medium, and large HMIWI assume 1.5 hours per week
to record operating parameters and parameter exceedances.





Assume 1 hour for recording CMS operation and maintenance records;
assume an average HMIWI operates 250 days per year.





	The labor requirements to train the personnel were estimated to be 8
hours per day for 5 days per year.



































	



	Table 2.  Average Annual EPA Resource Requirement for State and Federal
Emission Guidelines for Hospital/Medical/Infectious Waste Incinerators
(40 CFR part 60, subpart Ce and 40 CFR part 62, subpart HHH) 





































	(C)

(E)	(F)	(G)	(H)







(A)	(B)	EPA-hours

Technical	Management	Admin	Total	(I)





	EPA-hours	Number of	per facility	(D)	person-hours	person-hours
person-hours	hours	Total





	per	occurrences	per year	Facilities	per year	per year	per year	per year
Cost,

	Burden Item	occurrence	per year	(C = A x B)	per year	(E = C x D)	(F = E
x 0.05)	(G = E x 0.1)	(E)+(F)+(G)	$

	 1.	Attend initial performance test	32	1	32	0	0	0	0	0	0

	 2.	Repeat performance test











	A.	Retesting preparation	12	1	12	0	0	0	0	0	0



B.	Attend retesting	32	1	32	0	0	0	0	0	0

	 3.	Report review











	A.	Review reports for co-fired combustors













--Review notification of exemption claim	2	1	2	0	0	0	0	0	0



	--Review notification of relative amounts of hospital	2	1	2	0	0	0	0	0	0



	waste, medical/infectious waste, and other fuels and











	wastes to be combusted











	B.	Review notification of exemption claim for pathological,	2	1	2	0	0	0
0	0	0



	low-level radioactive, chemotherapeutic combustors











C.	Review reports of increments of progress













--Review control plan	4	1	4	0	0	0	0	0	0



	--Review notification of construction contracts	2	1	2	0	0	0	0	0	0



	--Review notification of construction commencement	2	1	2	0	0	0	0	0	0



	--Review notification of construction completion	2	1	2	0	0	0	0	0	0



	--Review notification of control plan completion	2	1	2	0	0	0	0	0	0



D. 	Review request for extension for HMIWI planning to shut	4	1	4	0	0	0
0	0	0



	down late











	E.	Review reports for small non-rural, medium and large











	HMIWI













--Review waste management plan	8	1	8	0	0	0	0	0	0



	--Review notification of initial performance test	8	1	8	0	0	0	0	0	0



	--Review notification of initial CMS demonstration	5	1	5	0	0	0	0	0	0



	--Review report of initial performance test	36	1	36	0	0	0	0	0	0



	--Review report of initial CMS demonstration	24	1	24	0	0	0	0	0	0



	--Review annual report













	--CMS operating parameters	6	1	6	66	396	19.8	39.6	455	$18,851.98





--Emissions/parameter exceedances and periods	16	1	16	13.2	211.2	10.6
21.1	243	$10,054.39





when emission/parameter data not obtained







 	 





--Results of annual performance test	24	1	24	66	1584	79.2	158.4	1,822
$75,407.90





--Report of no exceedances	8	1	8	53	424	21.2	42.4	488	$20,184.94



	--Review semiannual report of emissions/parameter	8	1	8	13.2	105.6	5.3
10.6	121	$5,027.19



	exceedances and periods when emission/parameter











	data not obtained











	F.	Review reports for small rural HMIWI













--Review waste management plan	8	1	8	0	0	0	0	0	0



	--Review notification of initial performance test	8	1	8	0	0	0	0	0	0



	--Review notification of initial CMS demonstration	5	1	5	0	0	0	0	0	0



	--Review report of initial performance test	30	1	30	0	0	0	0	0	0



	--Review report of initial CMS demonstration	8	1	8	0	0	0	0	0	0



	--Review annual report













	--CMS operating parameters	2	1	2	6	12	0.6	1.2	14	$571.27





--Emissions/parameter exceedances and periods	4	1	4	1.2	4.8	0.2	0.5	6
$228.51





when emission/parameter data not obtained



 



 	 





--Results of annual performance test	6	1	6	6	36	1.8	3.6	41	$1,713.82





--Report of no exceedances	2	1	2	4.8	9.6	0.5	1.0	11	$457.02





--Report of annual equipment inspection	4	1	4	6	24	1.2	2.4	28	$1,142.54







	(C)

(E)	(F)	(G)	(H)







(A)	(B)	EPA-hours

Technical	Management	Admin	Total	(I)





	EPA-hours	Number of	per facility	(D)	person-hours	person-hours
person-hours	hours	Total





	per	occurrences	per year	Facilities	per year	per year	per year	per year
Cost,

	Burden Item	occurrence	per year	(C = A x B)	per year	(E = C x D)	(F = E
x 0.05)	(G = E x 0.1)	(E)+(F)+(G)	$



	--Review semiannual report of emissions/parameter	2	1	2	1.2	2.4	0.1	0.2
3	$114.25



	exceedances and periods when emission/parameter





	 	 



	data not obtained







 	 

	4	Prepare annual summary report	1	1	1	72	72	3.6	7.2	83	$3,427.63

	TOTAL DESIGNATED ADMINISTRATOR BURDEN AND COST



2,882 	144 	288 	3,314	$137,181

































ASSUMPTIONS











	We estimate that there are 72 existing HMIWI, including approximately 6
small rural HMIWI, 2 small non-rural HMIWI, 20 medium HMIWI, and 44
large HMIWI.



	A zero value for number of respondents indicates that burden was
incurred prior to the time period covered by this supporting statement.





Costs are based on the following hourly rates:  technical at $42.45,
management at $57.20, and administrative at $22.96.





	Of the 20 percent (13.2 for small non-rural, medium, and large HMIWI;
1.2 for small rural) reported parameter exceedances 





	Assume 8 hours to review the waste management plan prepared by each of
the affected facilities.







	Assume 2 hours for review of notifications for increments of progress.









	Assume 4 hours for review of control plan.











	Assume 4 hours for review of request for extension.











	Assume 8 to review notification of initial performance test and CMS
demonstration









Assume 5 hours to review notification of initial CMS demonstration









	Assume 36 hours to review initial performance test (30 hours for small
rural HMIWI)









Assume 24 hours to review initial CMS demonstration (8 hours for small
rural HMIWI).









Assume 54 hours to review annual reports for small non-rural, medium and
large HMIWI.









Assume 18 hours to review annual reports for small rural HMIWI.











Assume 2 hours review emissions and parameter exceedances for the
semi-annual report. 









Assume 1 hour per facility when preparing the annual source and
emissions inventory update.





















	

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