STANDARD FORM 83 SUPPORTING STATEMENT

FOR ICR NO. 2164.02 ( REPORTING AND RECORDKEEPING REQUIREMENTS FOR
EMISSION GUIDELINES FOR EXISTING OTHER SOLID WASTE
INCINERATION(OSWI)UNITS

(40 CFR PART 60, SUBPART FFFF)  

	U.S. Environmental Protection Agency

	Office of Air Quality Planning and Standards

	Research Triangle Park, NC  27711

	

October 2005PART A OF THE SUPPORTING STATEMENT FOR STANDARD FORM 83

Other Solid Waste Incineration Units

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)  Title of the Information Collection.

"Reporting and Recordkeeping Requirements for Emission Guidelines for
Existing Other Solid Waste Incineration (OSWI) Units - (40 CFR Part 60,
Subpart FFFF)."

1(b)  Short Characterization/Abstract. 

This supporting statement addresses information collection activities
imposed by the Emission Guidelines for Other Solid Waste Incineration
(OSWI) Units ( 40 CFR Part 60 Subpart FFFF.  The emission guidelines
address existing OSWI units that commenced construction before proposal
of the emission guidelines (December 9, 2004).  The emission guidelines
do not apply directly to existing OSWI unit owners and operators.  The
emission 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 approvable State plan,
the Environmental Protection Agency (EPA) must develop a Federal plan to
implement the emission guidelines.  Whether an OSWI unit is ultimately
regulated under a State plan or Federal plan, the full respondent burden
for the first 3 years after promulgation of the emission guidelines is
included in this ICR.  The regulated OSWI units include two
subcategories: very small municipal waste combustion (VSMWC) units and
institutional waste incineration (IWI) units.

The use of the term "Designated Administrator" throughout this document
refers to the person or office designated by each State plan to
administer the implementation of the plan, or to the U.S. EPA
Administrator in the event that a State's plan is not approvable and a
Federal plan must be developed.  The term "Administrator" alone refers
to the U.S. EPA Administrator.

This ICR presents the burden to respondents and the Designated
Administrator (State or Federal Government).    Respondents are owners
or operators of existing OSWI units. 

This ICR includes the burden for activities that will be conducted in
the first three years following promulgation of the emission guidelines.
 Attachments A and B contain  tables of the respondent and agency burden
estimates, respectively, for years one through three.  These activities
include reading the rule.  Because the compliance date is 5 years after
the emission guidelines are promulgated, other activities, such as
testing, monitoring, recordkeeping, and reporting do not begin until
5 years after promulgation.  Therefore, they are not included in the
burden estimate for the first 3 years.  Although not necessary for this
ICR, respondent and agency burden estimates for years 4, 5, and 6 are
included in Attachments C and D to provide perspective on the annual
burden when the rule is fully implemented.

The requirements described below are the minimum requirements
established by the emission guidelines.  Although States may choose to
impose more stringent requirements, it is assumed for this burden
estimate that the State plans mirror the emission guidelines. 

1(c)  OMB Comments

      Prior to publication of a final rule, OMB requires that an agency
provide to OMB a summary of all public comments pertaining to the
information collection burden imposed by the rule and any changes made
in response to the comments.  No such comments regarding the information
collection burden imposed by the emission guidelines were received.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)  Need/Authority for the Collection

The EPA is charged under section 111(d) of the Clean Air Act (CAA), as
amended, to establish procedures by which:

. . .each State shall submit to the Administrator a plan which (A)
establishes standards of performance for any existing source for any air
pollutant. . .to which a standard of performance 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 CAA, to establish
guidelines for existing stationary sources that reflect the maximum
achievable control technology (MACT) for achieving continuous emission
reductions:

Section 129(a)(1) states:

The Administrator shall establish performance standards and other
requirements pursuant to section 111 and this section 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 or who is subject to any requirement of this Act . . .
to (A) establish and maintain such records, (B) make such reports,
(C) install, use, and maintain such monitoring equipment or methods,
(D) sample such emissions (in accordance with such methods, at such
locations, at such intervals, and in such manner as the Administrator
shall prescribe), and (E) provide such other information, as he 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 guidelines are being
achieved.

2(b)  Practical Utility/Users of the Data.

The information will be used by the 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 emission guidelines; (2) ensure that subpart FFFF is being
properly applied; (3) ensure that the emission limits are being
complied with; (4) ensure, on a continuous basis, that the operating
limits established during the initial performance test are not exceeded.

In addition, records and reports are necessary to enable the Designated
Administrator to identify OSWI units that may not be in compliance with
the emission guidelines. Based on reported information, the Designated
Administrator can decide which OSWI units should be inspected and what
records or processes should be inspected at the OSWI unit.  The records
that OSWI units maintain would indicate to the Designated Administrator
whether the personnel are operating and maintaining control equipment
properly and whether they have met the training qualification
requirements.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)  Nonduplication.

This ICR contains reporting and recordkeeping requirements for OSWI
units, whether regulated under a State plan or Federal plan.  No
information is required to be submitted in the first 3 years following
promulgation of the emission guidelines.

Other activities, such as emissions testing, operator training, and
monitoring of operating parameters, do not occur until 5 years after
promulgation.  This is because the final compliance date for existing
facilities occurs 5 years after promulgation of the emission guidelines
or 3 years after EPA approval of a State plan. 

In most cases, the enforcement of emission guidelines has been delegated
to State air pollution control agencies. In such cases, the reports
required by the emission guidelines will be submitted to the appropriate
State agency, and not directly to the EPA.  Thus, there is a minimal
possibility for the submittal of duplicate 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 OSWI facility.  The
facility owner or operator may submit a copy of State or local reports
to the Administrator in lieu of the report required by the emission
guidelines if it contains the necessary information, as specified in the
General Provisions of 40 CFR Part 60.

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

A public notice of this collection was provided in the notice of
proposed rulemaking for the emissions guidelines on December 9, 2004.

3(c)  Consultations.

While collecting technical information pertaining to the OSWI category,
EPA contacted incinerator manufacturers and associations as well as
State and Federal agencies.  In addition to these contacts, EPA
chartered an Industrial Combustion Coordinated Rulemaking advisory
committee in 1996, under the Federal Advisory Committee Act.  The
committee(s objective was to develop recommendations for regulations for
several combustion source categories under sections 112 and 129 of the
CAA.  The EPA considered information received from all of these sources
in the development of the emission guidelines. 

The public had the opportunity to review and comment on the proposed
emission guidelines and the ICR during the specified comment period.  

3(d)  Effects of Less Frequent Data Collection.

The emission guidelines require initial and annual performance tests for
nine pollutants and opacity, continuous emission monitoring for carbon
monoxide (CO), continuous operating parameter monitoring, annual
operator training, and annual reporting (semiannual deviation reports
are required if any of the emission limits or operating limits are
exceeded).  The frequency of these activities was chosen by EPA as the
period that will provide an adequate margin of assurance that affected
facilities will not operate for extended periods in violation of the
emission guidelines. 

No reports or data collection efforts are submitted in the first 3 years
after promulgation of the emission guidelines.  The only burden for
owners and operators in the first 3 years is to read and understand the
emission guidelines.  The other activities take place after the
compliance date, which will be in the fifth year after promulgation.

3(e)  General Guidelines.

With the exception of requiring records to be maintained for more than
3 years, none of the guidelines in 5 CFR 1320.5 are being exceeded. 
This rule requires all records to be maintained at the source for a
period of 5 years.  In 40 CFR Part 63, Subpart A, "General
Provisions for National Emission Standards for Hazardous Air Pollutants
for Source Categories," owners or operators of facilities are required
to keep and maintain records for a period of 5 years.  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 CAA, OSWI facilities are
subject to regulation under similar MACT-based regulations, therefore,
this 5-year record retention requirement was adopted for OSWI
facilities.  Furthermore, section 129 requires all OSWI units to obtain
title V operating permits under part 70 or 71 permit programs.  The
title V permit programs also require records to be retained for
5 years.  To minimize the burden, the emission guidelines allow files
to be kept in paper or electronic format.  Files must be kept on site
for 2 years but may be kept off site for the remaining 3 years. 

3(f)  Confidentiality.

All information submitted to EPA for which a claim of confidentiality is
made will be safeguarded according to EPA policies set forth in
title 40, chapter 1, part 2, subpart B -- Confidentiality of
Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976,
amended by 43 FR 39999, September 28, 1978; 43 FR 42251,
September 28, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions.  

This section is not applicable because this ICR does not involve matters
of a sensitive nature.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)  Respondents/NAICS Codes.

Respondents are owners or operators of OSWI units for which construction
commences on or before December 9, 2004. OSWI units include VSMWC units
that combust less than 35 tons per day of waste collected from multiple
residences, businesses, etc., that are operated by municipalities (NAICS
Codes 562213 and 92411).  OSWI units also include IWI units, as defined
in the regulation, that are located at an institutional facility and
combust waste generated at that facility.  IWI units can be located at
institutions such as schools, universities, prisons, military bases,
government facilities, churches and other institutions (NAICS Codes 623,
922, 928, 6111, 6112, 6113, 7121, 8131, and 8134). 

4(b)  Information Requested.

(i)  Data items.  The recordkeeping and reporting requirements of the
emission guidelines are described in section 4(b)(ii) and include the
following:

notification of final compliance (no information is required in the
first 3 years);

waste management plan;

records of operator training and qualification;

performance test reports;

records of CO and operating parameter monitoring;

annual compliance reports; and

semiannual deviation reports.

(ii)  Respondent activities.  The respondent activities required by the
emission guidelines are provided under the first column of Tables A1
through A3 in Attachment A.  As previously explained, the only
respondent activity in the first 3 years will be reading the rules.

There are no information collection activities in the first 3 years
after promulgation of the emission guidelines.

Any information collection activities included in the emission
guidelines will not occur until at least 5 years following promulgation.
 Therefore, the burden for these items is not included in the ICR,
however, burden estimate tables have been included as Attachment C. 
These items include:  preparation of a waste management plan,
performance tests, CO emissions monitoring, operating parameter
monitoring, operator training, one-time and periodic reports, and the
maintenance of records.

Testing and Monitoring:  The emission guidelines require an initial
performance test for particulate matter (PM), dioxins/furans, opacity,
hydrochloric acid (HCl), cadmium (Cd), lead (Pb), mercury (Hg), CO,
nitrogen oxides (NO ADVANCE \d3 x ADVANCE \u3 ) and sulfur dioxide (SO
ADVANCE \d3 2 ADVANCE \u3 ).  During the initial performance test, the
owner or operator must establish limits for each operating parameter. 
Thereafter, the owner or operator must conduct annual performance tests
for the nine pollutants and opacity, and must continuously monitor CO
and the operating parameters.  The emission guidelines allow the owner
or operator to skip two annual performance tests for a pollutant if all
performance tests over the previous 3 years show compliance with the
emission limit.

Operator Training:  To ensure the proper operation of the incinerator,
the emission guidelines require that each facility establish and
maintain at least one qualified OSWI unit operator or supervisor.  The
operator qualification process includes training, an exam, and review of
site-specific materials.  The operator qualification requirements allow
the flexibility to use State-approved training and qualification
programs.  To maintain qualification the operators or supervisors must
attend an annual refresher course and review site-specific materials
annually.

Reporting:  On or before the compliance date specified by the State or
Federal plan implementing the emission guidelines, the owner or operator
must submit a notification that includes a statement of compliance with
the emission guidelines.  Another report, the waste management plan,
identifies both the feasibility and the approach to separate certain
components of solid waste from the waste stream to reduce the amount of
toxic emissions from incinerated waste. The final compliance
notification and waste management plan are documents that need to be
prepared and submitted only once. 

Following the initial performance test, the owner or operator must
submit a report that documents the results of the performance test for
the nine pollutants and opacity and the values for the facility(s
operating limits. 

An annual compliance report is required that documents  the values for
the operating limits, performance test results and any deviations from
the emission limits, operating limits or other requirements.   

If there is a deviation from the operating limits or emission limits,
the owner or operator must submit a deviation report that provides
details on the deviation.  These reports are submitted semiannually if a
deviation occurs during the 6-month period.

Recordkeeping:  As specified in the emission  guidelines, owners or
operators of OSWI units are required to keep records of certain
parameters and information for a period of 5 years.  Owners or operators
are required to maintain records of the initial performance test, annual
performance tests, and any subsequent performance tests.  Owners or
operators must also maintain records of the monitoring data for CO and
the operating parameters, and records of monitoring device calibration.

Records must be maintained for any incinerator malfunctions, any
deviations from the operating limits, and days for which CO or operating
parameter monitoring data were not obtained.

Owners or operators must maintain the names of persons who have
completed the review of site-specific information and who have met the
operator qualification requirements.  Records of all documentation for
the waste management plan must also be maintained.

5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)  Agency Activities.

A list of Agency activities is provided in section 6(c) and in
Tables B1 through B3 in Attachment B.

5(b)  Collection Methodology and Management.  

This collection of information does not require the use of automated
collection techniques because of the relatively small number of
respondents, if any, that will be affected. See section 5(d) Collection
Schedule.

5(c)  Small Entity Flexibility. 

	The EPA does not expect the emission guidelines to have a significant
small business impact.  Therefore, the rule does not contain any
provisions reserved exclusively for the benefit of small entities. 
However, the rule does contain  provisions that reduce the impact of the
rule on all regulated entities, which include small entities.  Such
provisions include:  operating parameter monitoring is required instead
of continuous emissions monitoring systems(CEMS) for pollutants other
than CO; the owner or operator is allowed to skip two annual performance
tests for a pollutant if all performance tests over the previous
3 years show compliance; and semiannual deviation reports are only
required if there is a deviation, otherwise reporting is annual.  

5(d)  Collection Schedule.

In the first 3 years following promulgation of the emission guidelines,
owners or operators will only read the rule. 

In year 5 the information collected includes the following one-time-only
activities:  initial performance tests (PM, dioxins/furans, opacity,
HCl, Cd, Pb, Hg, CO,

NO ADVANCE \d3 x ADVANCE \u3 , SO ADVANCE \d2 2 ADVANCE \u2 ), initial
operator training and qualification, waste management plan, and report
following initial performance test (includes operating parameter
values).  The data will be entered into the Aerometric Information
Retrieval System (AIRS), operated and maintained by EPA(s Office of Air
Quality Planning and Standards.

After year 5, annual performance tests are required for the nine
pollutants listed above and opacity.  Continuous emission monitoring for
CO and continuous parameter monitoring is required.  An annual operator
training refresher course and site-specific information review is
required. 

An annual report is required that includes compliance data on the
operating limits, performance test results, and identification of
deviations from emission limits, operating limits, or other
requirements.

Additionally, if the operating limits or emission limits are exceeded,
the owner or operator must submit a deviation report that provides
details on the deviation.  If all qualified operators are unavailable
for more than 2 weeks, notification must be made within 10 days and a
status report must be submitted every 4 weeks until compliance with the
operator qualification requirements is achieved. 

Information obtained from annual compliance reports will be published
and distributed through the compliance data system (CDS).  Data obtained
during periodic visits by EPA personnel from records maintained by the
respondents will be tabulated and published for internal EPA use in
compliance and enforcement programs.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)  Estimating Respondent Burden.

The burden estimates are based on a population of 248 existing OSWI
units in EPA(s inventory.  Tables A1 through A3 in Attachment A present
an itemized breakdown of the reporting and recordkeeping requirements in
the first 3 years for the respondents subject to the emission
guidelines.  The annual cost and labor burden estimates for reporting
and recordkeeping show that the only requirement in the first 3 years is
reading and understanding the emission guidelines. 

6(b)  Estimating Respondent Costs. 

	The information collection activities for sources subject to these
requirements are presented in Tables A1 through A3 in Attachment A. 
The total cost for each respondent activity includes labor costs,
capital/startup costs, and operating and maintenance (O&M) costs.

(i)	Estimating Labor Costs.  Labor rates, on a per-hour basis, are taken
from the Bureau of Labor Statistics (BLS) Web site as posted in March
2004.  Attachment E contains the labor rate query results from the BLS
Web site. The occupational category that is the most similar to
personnel at facilities operating OSWI units is assumed to be (State and
local Government.(  The labor rates from the fourth quarter of 2003 have
been multiplied by a factor of 1.6 so that overhead and benefits are
included in the per-hour labor rates used to estimate respondent costs. 
The rates used are $46.02 for technical personnel, $67.04 for management
and $34.66 for clerical personnel.

(ii)  Estimating Capital and Operating and Maintenance Costs. 

There are no capital costs, operational costs or maintenance costs
associated with the emission guidelines in the first 3 years. 

(iii) Capital/Start-up Operating and Maintenance (O&M) Costs. 

There are no capital costs, or start-up operational or maintenance costs
associated with the emission guidelines in the first 3 years.

(iv) Annualizing Capital Costs.

There are no capital costs associated with the emission guidelines in
the first 3 years. 

6(c)  Estimating Agency Burden and Cost.

Because the information collection requirements were developed as an
incidental part of the emission guidelines  development, no costs can be
attributed to the development of the additional information collection
requirements.   Publication and distribution of the information are part
of the AIRS Facility subsystem, with the result that no Federal costs
can be directly attributed to the ICR.  Examination of records to be
maintained by the respondents will occur incidentally as part of the
periodic inspection of sources that is part of the Designated
Administrator(s overall compliance and enforcement program and,
therefore, can not be attributable to the ICR.  

The only costs that the Implementing Agency will incur in the first 3
years are reading and understanding the rule, and preparing an annual
report that summarizes progress in implementing State plans and the
compliance status of the affected facilities in each State.  These items
are presented in Tables B1 through B3 in Attachment B.  Under 40 CFR
Part 60, Subpart B, the first annual State progress reports are required
at the end of the first full calendar year after approval of the State
plan or promulgation of the Federal plan.  Section 129 of the CAA allows
1 year for States to submit a State plan.  The EPA will approve the plan
or promulgate a Federal plan, if needed, in the second year.  Year three
will be the first year after approval of State plans or promulgation of
the Federal plan and, therefore, the first year States or EPA need to
submit State progress reports. 

Labor rates for the Designated Administrator(s employees are also based
on the estimated hourly rates for (State and local Government,( as
described above for the respondent labor costs, and are:  $46.02 for
technical personnel; $67.04 for management personnel; and $34.66 for
clerical personnel. 

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

The total number of respondents is also referred to as the respondent
universe.  The respondent universe for this ICR is based on EPA(s OSWI
inventory database, which shows 248 OSWI units currently in operation. 
Almost every respondent owns/operates one OSWI unit.  Industry burden is
calculated based on the assumption that all existing OSWI units will
remain in use during years one through three.  

6(e)  Bottom Line Burden Hours and Cost Tables.

(i)  The Respondent Tally.  A breakdown for each of the collection,
reporting, and recordkeeping activities required by the emission
guidelines is presented in Tables A1 through A3 in Attachment A.  The
estimate of total annual hours requested from the respondents was based
on the assumptions outlined in section 6(d) of this ICR.  The EPA
estimated the respondent burden for the first 3 years after adoption of
the emission guidelines by totaling the hours per year for technical,
managerial, and clerical staff at the facility.  Due to the absence of
capital or start-up costs in the first 3 years, there are no annualized
capital costs.  There are also no operating and maintenance costs in the
first 3 years.  The average annual respondent burden for the 3-year
period is 3,803 hours and $174,703 of labor costs.

(ii)  The Designated Administrator.  The bottom line Designated
Administrator burden hours and costs, presented in Tables B1 through B3
in Attachment B, were calculated by totaling the hours per year for
technical, managerial, and clerical staff, and by totaling the cost
column.  The average annual Agency burden over the first 3 years is
383 hours and $17,611 of labor costs.  There are no capital, start-up
or operating and maintenance costs in the first 3 years. 

(iii)  Variations in the Annual Bottom Line.  The total respondent costs
for years 1, 2, and 3 are $524,109, $0 and $0, respectively.  The
corresponding total number of respondent hours during this period are
11,408 hours, 0 hours, and 0 hours (see Table A4 in Attachment A).  The
only activity during this period is reading and understanding the rule.

Most of the burden of the rule, such as initial and annual performance
tests, operator training and qualification, monitoring of operating
parameter values, and reporting and recordkeeping for these activities,
will not occur until year 5.  Therefore, the respondent burden for
years 1 through 3 is minimal.  

During the first 3 years, the Designated Administrators will be
reviewing the regulation, and preparing annual summary reports.  In
years 1, 2, and 3, the Designated Administrators will expend 920, 0,
and 230 total hours in labor, respectively.  The corresponding costs for
each year are $42,267, $0, and $10,567 (see Table B4 in Attachment B). 

6(f)  Reasons for Change in Burden.  

Updated information for the OSWI Inventory Database showed that several
facilities previously included in the respondent universe have closed. 
This change led to a decrease in the burden estimate since the estimate
made at proposal of the emission guidelines.

6(g) Burden Statement.

Burden means total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.  An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 
The OMB control numbers for EPA(s regulations are listed in
40 CFR part 9 and 48 CFR chapter 15.

  SEQ CHAPTER \h \r 1  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-OAR-2003-0156, which is available
for online viewing at   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov , or in person viewing at the Air and Radiation
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room B102, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Air and Radiation Docket and Information Center is (202) 566-1742.  An
electronic version of the public docket is available at
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.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OAR-2003-0156 in any correspondence.

	PART B OF THE SUPPORTING STATEMENT

	This section is not applicable because statistical methods are not used
in data collection associated with this regulation.	ATTACHMENT A

	TABLES A1, A2, A3, and A4

	(For Tables A1 through A3, see 

	Excel Spreadsheet EG-OSWI-Cost yrs 1-6)

Table A1:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 1

Table A2:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 2

Table A3:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 3

Table A4:	Summary of Respondent Burden for Emission Guidelines - Years 1
through 3 

	TABLE A4.  SUMMARY OF RESPONDENT BURDEN FOR EMISSION GUIDELINES - YEARS
1 THROUGH 3

	

	

	

	

	

	

	

Non-Labor Costs	





Year 	

Technical Hours	

Management Hours	

Clerical Hours	

Contractor Hours	

Total Hours	

Labor Costs	

Capital	

O&M 	

Total Cost



Year 1	

9,920	

496	

992	

0	

11,408	

$524,109	

0	

0	

$524,109



Year 2	

0	

0	

0	

0	

0	

0	

0	

0	

0



Year 3	

0	

0	

0	

0	

0	

0	

0	

0	

0



Totals	

9,920	

496	

992	

0	

11,408	

$524,109	

0	

0	

$524,109



Average Burden Per Year	

3,307	

165	

331	

0	

3,803	

$174,703	

0	

0	

$174,703



Note:  All figures are rounded to nearest dollar or hour.

	ATTACHMENT B

	TABLES B1, B2, B3, and B4

	(For Tables B1 through B3, see 

	Excel Spreadsheet EG-OSWI-Cost yrs 1-6)

Table B1:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 1

Table B2:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 2

Table B3:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 3

Table B4:	Summary of Designated Administrator Burden for Emissions
Guidelines - Years 1 through

TABLE B4.  SUMMARY OF DESIGNATED ADMINISTRATOR FOR EMISSION GUIDELINES 

- YEARS 1 THROUGH 3 

Agency Burden Summary:	

	

	

	

	





	

Technical Hours	

Management Hours	

Clerical

Hours	

Total

Hours	

Labor 

Costs



Year 1	

800	

40	

80	

920	

$42,267



Year 2	

0	

0	

0	

0	

0



Year 3	

200	

10	

20	

230	

$10,567



Totals	

1,000	

50	

100	

1,150	

$52,834



Average Burden Per Year	

333	

17	

33	

383	

$17,611



Note:  All figures are rounded to the nearest dollar or hour.

	ATTACHMENT C

	TABLES C1, C2 and C3

	(For Tables C1 through C3, see 

	Excel Spreadsheet EG-OSWI-Cost yrs 1-6)

Table C1:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission  Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 4

Table C2-A:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 5 (All Comply)

Table C2-B:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 5 (All Close)

Table C3-A:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 6 (All Comply)

Table C3-B:	Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for OSWI Facilities
Subject to Subpart FFFF - Year 6 (All Close)

	ESTIMATED RESPONDENT BURDEN FOR 

	YEARS 4, 5, and 6

The following tables display the estimated respondent burden for the
fourth, fifth and sixth years following promulgation of the OSWI
emission guidelines (40 CFR 60 subpart FFFF).  These tables are
presented as an example of the burden expected beyond the first three
years discussed in the supporting statement and presented in attachment
A.  The burden increases in year 5 because the compliance date for the
emission guidelines is 5 years after promulgation.

Table C1 presents the burden and costs for year 4 following
promulgation.  During this year, there are no required activities such
as testing, reporting, recordkeeping, etc. and, as such, no expected
costs to respondents.  We anticipate that any activities needed to
demonstrate compliance with the emission guidelines, such as CEMS
installation and emissions testing, will not occur until year 5. 

Tables C2-A and C2-B present the year 5 respondent burden and cost for
two possible scenarios which may occur with existing OSWI units ( one
where all units comply with the emission guidelines (C2-A), and another
where all units close and utilize alternative waste disposal options
(C2-B). The EPA(s experience with other CAA section 129 regulations has
shown that sources will likely respond to the emission guidelines by
choosing to shut down existing waste incineration units and utilizing
alternative waste disposal options rather than incur the costs of
compliance.  The EPA(s objective is not to encourage the use of
alternatives or to discourage continued use of VSMWC units or IWI units;
EPA(s objective is to adopt emission guidelines for existing OSWI units
that fulfill the requirements of CAA section 129. In doing so, however,
the primary outcome associated with the adoption of these emission
guidelines is projected to be an increase in the use of alternative
waste disposal and a decrease in the use of VSMWC and IWI units.  As a
result, we present burden and cost estimates for both possible scenarios
for existing OSWI units.

Table C2-A presents the burden and cost associated with initial
compliance demonstration, including CEMS costs and the initial
performance test, assuming that all existing OSWI units choose to comply
with the emission guidelines.  Table C2-B presents the year 5 respondent
burden and cost for all existing OSWI units, assuming that all units
close down and utilize alternative waste disposal options.

The tables for year 6 also present the two scenarios presented for year
5.  Table C3-A presents the year 6 respondent burden assuming that all
existing OSWI units comply with the emission guidelines.  Ongoing
compliance demonstration activities and associated recordkeeping and
reporting activities, such as continuous monitoring, annual emissions
testing, annual compliance reporting, and deviation reporting are
included.  While not shown on this table, it is noteworthy that the
emission guidelines provide provisions for sources to skip annual
performance testing if they have demonstrated sustained good performance
(i.e., if you have at least three consecutive annual tests that show
that you comply with the emission limit for a pollutant, then you do not
have to conduct a performance test for that pollutant for the next 2
years).  Therefore, the annual burden may decrease in later years as
sources become eligible for the skip testing provisions.  Table C3-B,
which shows no costs or burden, presents the year 6 respondent burden
assuming all existing OSWI units close down and utilize alternative
waste disposal options.

	ATTACHMENT D

	TABLES D1, D2, and D3

	(For Tables D1 through D3, see 

	Excel Spreadsheet EG-OSWI-Cost yrs 1-6)

Table D1:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 4

Table D2-A:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 5 (All Comply)

Table D2-B:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 5 (All Close)

Table D3-A:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 6 (All Comply)

Table D3-B:	Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the  Emission Guidelines for
OSWI Facilities Subject to Subpart FFFF - Year 6 (All Close)

	ESTIMATED DESIGNATED ADMINISTRATOR 

	BURDEN FOR YEARS 4, 5, and 6

The following tables display the estimated Designated Administrator
burden for the fourth, fifth and sixth years following promulgation of
the OSWI emission guidelines (40 CFR 60 subpart FFFF).  These tables are
presented as an example of the burden expected beyond the first three
years discussed in the supporting statement and presented in attachment
B.  The burden increases in year 5 because the compliance date for the
emission guidelines is 5 years after promulgation.

Table D1 presents the burden and costs for year 4 following
promulgation.  During this year, the only required Designated
Administrator activity is the preparation of an annual summary report. 
We anticipate that activities needed to demonstrate compliance with the
emission guidelines, such as observing and reviewing initial performance
tests and review of final compliance reports, will not occur until year
5.

Tables D2-A and D2-B present the year 5 Designated Administrator burden
and cost for two possible scenarios which may occur with existing OSWI
units ( one where all units comply with the emission guidelines (D2-A),
and another where all units close and utilize alternative waste disposal
options (D2-B).  The EPA(s experience with other CAA section 129
regulations has shown that sources will likely respond to the emission
guidelines by choosing to shut down existing waste incineration units
and utilizing alternative waste disposal options rather than incur the
costs of compliance.  The EPA(s objective is not to encourage the use of
alternatives or to discourage continued use of VSMWC units or IWI units;
EPA(s objective is to adopt emission guidelines for existing OSWI units
that fulfill the requirements of CAA section 129.  In doing so, however,
the primary outcome associated with the adoption of these emission
guidelines is projected to be an increase in the use of alternative
waste disposal and a decrease in the use of VSMWC and IWI units.  As a
result, we present burden and cost estimates for both possible scenarios
for existing OSWI units.

Table D2-A presents the burden and cost associated with initial
compliance demonstration, including observation of the initial
performance tests, review of final compliance notifications, waste
management plan reviews, and initial compliance test report reviews,
assuming that all existing OSWI units choose to comply with the emission
guidelines.  Table D2-B presents the year 5 Designated Administrator
burden and cost, assuming that all units close down and utilize
alternative waste disposal options.

The tables for year 6 also present the two scenarios as with year 5. 
Table D3-A presents the year 6 Designated Administrator burden assuming
that all existing OSWI units comply with the emission guidelines. 
Ongoing compliance demonstration activities, such as observing annual
performance tests, review of semi-annual deviation reports, and review
of annual compliance reports are included in the cost and burden.  While
not shown on this table, it is noteworthy that the emission guidelines
provide provisions for sources to skip annual performance testing if
they have demonstrated sustained good performance (i.e., if you have at
least three consecutive annual tests that show that you comply with the
emission limitation for a pollutant, then you do not have to conduct a
performance test for that pollutant for the next 2 years).  Therefore,
the annual burden associated with observing annual performance tests may
decrease in later years as sources become eligible for the skip testing
provisions.  Table D3-B, which shows no costs or burden, presents the
year 6 Designated Administrator burden assuming all existing OSWI units
close down and utilize alternative waste disposal options.



ATTACHMENT E

BUREAU OF LABOR STATISTICS INFORMATION

(For the BLS Web site printouts, see 

Adobe PDF file BLSdata.pdf)

 PAGE   

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 PAGE   19 

C- PAGE   2 

D- PAGE   3 

