SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Small Municipal Waste Combustors (40 CFR Part 60, Subpart AAAA)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Small Municipal Waste Combustors (40 CFR Part 60, Subpart AAAA)
(Renewal)

EPA ICR Number 1900.04, OMB Control Number 2060-0423

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subpart AAAA were proposed on August 30,
1999, and promulgated on December 6, 2000.  These regulations apply to
the following facilities in small municipal waste combustors (MWCs) that
combust greater than 35 tons per day (tpd) but less than 250 tpd of
municipal solid waste: small MWCs commencing construction after August
30, 1999, and small MWC units that commenced reconstruction or
modification after June 6, 2001.  This information is being collected to
assure compliance with 40 CFR part 60, subpart AAAA.

In general, all NSPS require initial notifications, performance tests,
and periodic reports.  Owners or operators also are 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 and are
required of all sources subject to NSPS.  This Information Collection
Request (ICR) will enable the U.S. Environmental Protection Agency (EPA)
to monitor compliance with emission standards for regulated pollutants. 
Owners and operators of small MWCs are required to measure, record, and
report emission rates and operating parameters, follow good combustion
practices, and submit a siting analysis.

	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 delegated state or local
authority.   In the event that there is no such delegated authority, the
reports are sent directly to the EPA regional office.

Approximately four small MWC units (i.e., sources) at two plants (i.e.,
respondents) are subject to the regulation, and it is estimated that one
additional privately owned MWC unit (therefore, potentially one
additional private industry respondent) will become subject to the
regulation in the next three years.

The burden to the affected public, the owners or operators of small MWCs
commencing construction after August 30, 1999, or commencing
reconstruction or modification after June 6, 2001, is listed below in
Table 1a: Annual Private Respondent Burden and Cost of Recordkeeping and
Reporting Requirements for the NSPS for Small Municipal Waste Combustors
(40 CFR part 60, subpart AAAA) (Renewal) and Table 1b: Annual
State/Local Government Respondent Burden and Cost of Recordkeeping and
Reporting Requirements for the NSPS for Small Municipal Waste Combustors
(40 CFR part 60, subpart AAAA) (Renewal).  One currently subject plant
is owned privately, and one plant is owned publically (local
government).           The Federal government burden, such as the review
of reports submitted by the respondents, is attributed entirely to work
performed by Federal employees or government contractors and is shown in
Table 2: Annual Agency Burden for the NSPS for Small Municipal Waste
Combustors (40 CFR part 60, subpart AAAA) (Renewal).

The Office of Management and Budget (OMB) approved the currently active
ICR without any “Terms of Clearance.”

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.

 

In the Administrator’s judgment, organics, metals, and acid gases
emissions from small MWCs cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare.  MWC
organics consist of doxins/furans.  MWC metals are cadmium, lead,
mercury, and particulate matter.  MWC acid gases consist of hydrogen
chloride, sulfur dioxide, and nitrogen oxides.  Therefore, the NSPS were
promulgated for this source category at 40 CFR part 60, subpart AAAA.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure
compliance with the applicable regulations that were promulgated in
accordance with the Clean Air Act.  The collected information also is
used for targeting inspections and as evidence in legal proceedings.

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

The notifications required in the standards are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to check if the pollution control devices are
properly installed and operated and that the standards are being met. 
The performance test also may be observed.

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

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, subpart AAAA.

3(a)  Non-duplication

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 (74 FR 32580) on July 8, 2009.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The Agency’s industry experts have been consulted regarding the
current number of affected facilities and to project industry growth
over the next three years.  The EPA Office of Air Quality Planning and
Standards maintains a facility and emissions inventory for municipal
waste combustors.  The universe of sources subject to the standard and
the growth rate for the industry are based on our consultations with the
Agency’s internal industry experts who maintain and utilize this
inventory.  

Approximately one new private respondent will be subject to the standard
over the three-year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed, and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.  In this case, no comments were received.


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 and 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
small municipal waste combustors.  The United States Standard Industrial
Classification (SIC) codes and the associated North American Industry
Classification System (NAICS) codes for possible respondents affected by
the standards are listed in the table below.

Regulation	SIC Codes	NAICS Codes

40 CFR part 60, subpart AAAA	9511 Air & Water Resource and Solid Waste
Management	92411 Air & Water Resource and Solid Waste Management

	4953 Refuse System	562213 Solid Waste Combustors & Incinerators



	4(b)  Information Requested

		(i)  Data Items

	In this ICR, all the data that is recorded or reported is required by
NSPS for Small Municipal Waste Combustors (40 CFR part 60, subpart
AAAA).

A source must make the following reports:

  SEQ CHAPTER \h \r 1 Reports for NSPS Small Municipal Waste Combustors
(40 CFR part 60, subpart AAAA)

Construction/reconstruction	60.7(a)(1), 60.1375 

Reports due before and after notice of construction	60.1375 60.1385

Actual startup	60.7(a)(3), 

Initial stack tests for all regulated pollutants and parameters	60.8(a)
and (d), 60.1395, 60.1400 60.1430

Notice of construction	 60.1380

Semi-annual reports	60.1415 - 60.1420, 60.1430

Annual compliance reports for all pollutants and parameters	60.1405,
60.1410, 60.1430

Reports for air curtain incinerators	60.1455

Demonstration of continuous monitoring system and test data	60.7(a)(5),
60.1395

Physical or operational change	60.7(a)(4)

Semiannual excess emission reports (SO ADVANCE \d 2 2 ADVANCE \u 2 , CO,
load, temperature, PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg,
fugitives)	60.1425

Report of continuous emission monitors (CEMs) demonstration and test
data	60.1410



A source must keep the following records:

  SEQ CHAPTER \h \r 1 Recordkeeping for NSPS Small Municipal Waste
Combustors (40 CFR part 60, subpart AAAA)

Records of occurrence and duration of any startups, shutdowns,
malfunctions, or any malfunction of CEMS	60.7(b), 60.1340, 60.1365

Records on material separation plan and siting analysis	60.1345(a)
60.1350

Records of operator training and certification	60.1340(b), 60.1355

Records of initial stack tests and annual stack tests	60.1340(c),
60.1360

Records for CEMS rates and parameters and computations of average
emissions and parameters	60.1340(d), 60.1365, 60.1370

Records of MWC units that use activated carbon.  Records of quarterly
amount of sorbent for Hg control	60.1340(e), 60.1370

Records of results of daily CEMS drift tests and Appendix F accuracy
assessments	60.1365

Records are required to be retained for 5 years.  The full 5 years of
records must be retained at the facility	60.1345



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.  It is estimated
that approximately 10 percent of all general respondents in any industry
use electronic reporting.

(ii)  Respondent Activities

  SEQ CHAPTER \h \r 1 Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CEMS for opacity, SO2, NOX,
O2.

Perform initial and annual performance tests, Reference Methods 1 and 23
for organics; Reference Methods 1 and 29 for Cd, Pb, Hg; Reference
Method 9 for opacity; Reference Methods 1 and 5 for particulate matter;
Reference Methods 1and 26 or 26A for acid gases; and Reference Method 22
for fugitive ash.  Repeat performance tests if necessary.

Conduct quarterly Appendix F audits of CEMS.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

Adjust the existing ways to comply with any previously applicable
instructions and requirements.

Train personnel to be able to respond to a collection of information. 
Ensure operators’ training and certification.

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 AFS, which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses 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

Small MWC units potentially affected by the NSPS also are owned by small
businesses, non-profit organizations, or governments.  The EPA does not
expect the standards to adversely affect these small entities.  The
standards only apply to units with capacities between 35 tpd and 250
tpd.  Furthermore, the standards contain provisions for reduced testing.
 Owners of some small MWC units can skip annual tests for two-year
periods for certain pollutants if they have demonstrated compliance for
three annual tests in a row.  In addition to this reduced testing
option, less frequent dioxin/furan testing is possible if all MWC units
at a plant achieve emission levels less than the emission limit for two
consecutive years.  This provision allows plants to test only one unit
per year rather than all units, as normally required.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1a: Annual Private Respondent
Burden and Cost of Recordkeeping and Reporting Requirements for the NSPS
for Small Municipal Waste Combustors (40 CFR part 60, subpart AAAA)
(Renewal) and Table 1b: Annual State/Local Government Respondent Burden
and Cost of Recordkeeping and Reporting Requirements for the NSPS for
Small Municipal Waste Combustors (40 CFR part 60, subpart AAAA)
(Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1a (private respondents) and Table 1b (state/local governments)
document the computation of the individual, respective 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 combined average annual burden to both private and state/local
entities in this industry over the next three years from these
recordkeeping and reporting requirements is estimated to be 9,975 hours.
 These hours are based on Agency studies and background documents from
the development of the regulation, Agency knowledge and experience with
the program, the previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$114.77 ($54.65 + 110%)

Technical	$97.59   ($46.47 + 110%)

Clerical	$48.26   ($22.98 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, Table 2. “Employer costs per hour worked for
employee compensation and costs as a percent of total compensation:
Civilian workers, by occupational and industry group,” March 2009. 
The rates are from the column “Total compensation”.  The rates have
been increased by 110 percent 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 both private and state/local entities in the industry
costs associated with the information collection activities in the
subject standards are both labor costs, which are addressed elsewhere in
this ICR, and the costs associated with continuous monitoring.  The
capital/startup costs are one-time costs when a facility becomes subject
to the regulation.  The annual operation and maintenance costs are the
ongoing costs to maintain the monitors and other costs such as
photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Affected Facility	(C)

Number of New Facilities	(D)

Total Capital/Startup Cost, (B x C)	(E)

Annual O&M Costs for One Facility	(F)

Number of Facilities with O&M	(G)

Total O&M,

(E x F)

Load monitors, temperature monitors, and carbon federate monitors
(Sections 60.1315 thru 60.1335)	$200,000	0.33a	$66,000	$19,200	4.33b
$83,136

a We estimate that one additional facility will become subject to this
subpart over the next three years.  Therefore, we estimate the number of
new facilities to be 0.33 per year.

b The estimated number of facilities with O&M costs includes the four
existing facilities and the one additional facility (0.33 per year)
expected to startup over the next three years.

The total capital/startup cost for this ICR is $66,000.  This is the
total of column D in the above table.  

The total operation and maintenance (O&M) cost for this ICR is $83,136. 
This is the total of column G.  

The average annual cost for capital/startup and operation and
maintenance costs to both the private and state/local entities of this
industry over the next three years of the ICR is estimated to be a
combined total of $149,136.  

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $25,480 (rounded).

This cost is based on the average hourly labor rate as follows:

Managerial	$61.36  (GS-13, Step 5, $38.35 x 1.6)

Technical	$45.52  (GS-12, Step 1, $28.45 x 1.6)

Clerical	$24.64  (GS-06, Step 3, $15.40 x 1.6)

These rates are from the Office of Personnel Management “2009 General
Schedule,” which excludes locality rates of pay.  The rates have been
increased by 60 percent to account for the benefit packages available to
government employees.  Details upon which this estimate is based appear
below in Table 2: Annual Agency Burden for the NSPS for Small Municipal
Waste Combustors (40 CFR part 60, subpart AAAA) (Renewal).

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, two existing respondents will be subject to the standard.  It is
estimated that one additional respondent will become subject to this
standard over the next three years.  The overall average number of
respondents, as shown in the table below, is 2.33 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 1	(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	0.33	2	0	0	2.33

2	0.33	2	0	0	2.33

3	0.33	2	0	0	2.33

Average	0.33	2	0	0	2.33

1We are assuming that one additional respondent starts up over the
period of this ICR.

As shown above, the average Number of Respondents over the three-year
period of this ICR is 2 (rounded).  

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 Per Respondent Per Year	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Plant Startup (Waste Separation Plan, Notifications, etc.)	0.33	4	0	1.32

Notifications (Performance Test, CEMS Demonstration, etc.)	0.33	4	0	1.32

Annual Reports	2.33	1.86	0	4.33

Semiannual Excess Emission Reports	1	2	0	2

Total



9 (Rounded)



The number of Total Annual Responses is nine (9).  

The total annual labor costs are $938,068.  Details regarding these
estimates may be found in Table 1a: Annual Private Respondent Burden and
Cost of Recordkeeping and Reporting Requirements for the NSPS for Small
Municipal Waste Combustors (40 CFR part 60, subpart AAAA) (Renewal) and
Table 1b: Annual State/Local Government Respondent Burden and Cost of
Recordkeeping and Reporting Requirements for the NSPS for Small
Municipal Waste Combustors (40 CFR part 60, subpart AAAA) (Renewal).

The total annual capital/startup and O&M costs to the regulated entities
are $149,136. 

The average annual Agency burden and cost over next three years is
estimated to be 574 labor hours at a cost of $25,480.  See below Table
2: Annual Agency Burden for the NSPS for Small Municipal Waste
Combustors (40 CFR part 60, subpart AAAA) (Renewal).

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

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1a/b and 2, respectively,
and summarized below.

(i) Respondent Tally

The total annual hours are 9,975.  Details regarding these estimates may
be found below in Table 1a: Annual Private Respondent Burden and Cost of
Recordkeeping and Reporting Requirements for the NSPS for Small
Municipal Waste Combustors (40 CFR part 60, subpart AAAA) (Renewal) and
Table 1b: Annual State/Local Government Respondent Burden and Cost of
Recordkeeping and Reporting Requirements for the NSPS for Small
Municipal Waste Combustors (40 CFR part 60, subpart AAAA) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 1,108 hours per
response.

The total annual capital/startup and O&M costs to the regulated entity
are $149,136. 

(ii) The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 574 labor hours at a cost of $25,480.  See below Table
2: Annual Agency Burden for the NSPS for Small Municipal Waste
Combustors (40 CFR part 60, subpart AAAA) (Renewal).

6(f)  Reasons for Change in Burden

The adjustment decrease in burden from the most recently approved ICR is
an adjustment due to a decrease in the number of respondents, from three
to two.  Small units at one location were replaced with large units,
which are not subject to this rule.  

Capital/startup and O&M costs [section 6(b)(iii)] also decreased
compared to the previous ICR.  The previous ICR has identical
capital/startup costs, but this ICR has lower O&M costs.  The decrease
is attributed to the fact that one less unit is operating.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 1,108 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-2009-0383.  An electronic version of the public docket is
available at http://www.regulations.gov and may be used to obtain a copy
of the draft collection of information, submit, or view public comments,
access the index listing of the contents of the 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 in this document.  The documents are also available
for public viewing at the Enforcement and Compliance Docket and
Information Center in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 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 docket
center is (202) 566-1752.  Also, you can 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 ID Number EPA-HQ-OECA-2009-0383 and OMB
Control Number 2060-0423 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 1a.  Annual Private Respondent Burden
and Cost of Recordkeeping and Reporting Requirements for the NSPS for
Small Municipal Waste Combustors (40 CFR part 60, subpart AAAA)
(Renewal)

Burden Item	(A)

Respondent Hours Per Occurrence	(B)

Number of Occurrences Per Respondent Per Year	(C)

Person Hours Per Respondent Per Year (C=AxB)	(D)

Number of Respondents Per Year	(E)

Technical Hours Per Year (E=CxD)	(F)

Management Hours Per Year (F=Ex0.05)	(G)

Clerical Hours Per Year (G=Ex0.1)	(H)

Total Hours Per Year (H=E+F+G)	(I)

Total Cost Per Year

1	Applications	Not applicable	 	 	 	 	 	 	 	 

2	Surveys and Studies	Not applicable	 	 	 	 	 	 	 	 

3	Reporting Requirements	 	 	 	 	 	 	 	 	 

 	A.	Read and Understand Rule Requirements	40	1	40	1	40	2	4	46
$4,326.18 

 	B.	Required Activities	 	 	 	 	 	 	 	 	 

 	 	1) Initial performance tests and reports (PM, dioxins/furans,
opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	1	775	38.75	77.50	891.25
$83,819.74 

 	 	2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)	 	 	 	 
 	 	 	 	 

 	 	 	a) Installation of CEM units	225	1	225	1	225	11.25	22.50	258.75
$24,334.76 

 	 	 	b) Initial demonstration	450	1	450	1	450	22.50	45	517.50
$48,669.53 

 	 	3) Annual performance tests and test reports (PM, dioxins/furans,
opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	1	775	38.75	77.50	891.25
$83,819.74 

 	 	4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)	 	 	 	 
 	 	 	 	 

 	 	 	a) RATA audit (one per year)	350	1.86	651	1	651	32.55	65.10
748.65	$70,408.58 

 	 	 	b) RAA audit (three per year)	130	5.58	725.40	1	725.40	36.27
72.54	834.21	$78,455.27 

 	 	 	c) Daily calibration and operation	1	678.90	678.90	1	678.90
33.95	67.89	780.74	$73,426.09 

 	C.	Create Information	Included in 3.B	 	 	 	 	 	 	 	 

 	D.	Gather Information	Included in 3.E	 	 	 	 	 	 	 	 

 	E.	Report Preparation	 	 	 	 	 	 	 	 	 

 	 	1) Plant startup	 	 	 	 	 	 	 	 	 

 	 	 	a) Preliminary and final material separation plans and siting
analysis	270	1	270	1	270	13.50	27.00	310.50	$29,201.72 

 	 	 	b) Public meeting and comment response	140	1	140	1	140	7	14.00
161	$15,141.63 

 	 	 	c) Notification of construction	2	1	2	1	2	0.10	0.20	2.30
$216.31 

 	 	 	d) Notification of startup	2	1	2	1	2	0.10	0.20	2.30	$216.31 

 	 	2)  Notification of initial performance tests	4	1	4	1	4	0.20	0.40
4.60	$432.62 

 	 	3)  Initial compliance reports	40	1	40	1	40	2	4.00	46	$4,326.18 

 	 	4)  Notification of CEMS demonstration	4	1	4	1	4	0.20	0.40	4.60
$432.62 

 	 	5)  Initial CEMS demonstration report	40	1	40	1	40	2	4.00	46
$4,326.18 

 	 	6)  Annual compliance reports	40	1.86	74.40	1	74.40	3.72	7.44
85.56	$8,046.69 

 	 	7)  Semi-annual excess emission reports	40	2	80	0.5	40	2	4.00	46
$4,326.18 

 	Subtotal - Reporting Requirements	 	 	 	 	 	 	 	5,677.21
$533,926.32

4	Recordkeeping Requirements	 	 	 	 	 	 	 	 	 

 	A.	Read Instructions	Included in 3.A	 	 	 	 	 	 	 	 

 	B.	Plan Activities	Included in 3.B	 	 	 	 	 	 	 	 

 	C.	Implement Activities	Included in 3.B	 	 	 	 	 	 	 	 

 	D.	Develop Record System	Not applicable	 	 	 	 	 	 	 	 

 	E.	Record information	 	 	 	 	 	 	 	 	 

 	 	1) Record startups, shutdowns, and malfunctions	4	47	188	1	188
9.40	18.80	216.20	$20,333.05 

 	 	2) Records of all emission rates, computations, tests	4	47	188	1
188	9.40	18.80	216.20	$20,333.05 

 	 	3) Records of employee review of operations manual	4	1	4	1	4	0.20
0.40	4.60	$432.62 

 	 	4) Record amount of sorbent used for Hg and dioxin/furan control	4
4	16	1	16	0.80	1.60	18.40	$1,730.47 

 	F.	Personnel Training	Not applicable	 	 	 	 	 	 	 	 

 	G.	Time for audits	Not applicable	 	 	 	 	 	 	 	 

 	Subtotal - Recordkeeping Requirements	 	 	 	 	 	 	 	455.40
$42,829.18

TOTAL LABOR BURDEN AND COST: 	 	 	 	 	 	 	 	6,133 (Rounded)
$576,756 (Rounded) 



Table 1b.  Annual State/Local Government Respondent Burden and Cost of
Recordkeeping and Reporting Requirements for the NSPS for Small
Municipal Waste Combustors (40 CFR part 60, subpart AAAA) (Renewal)

Burden Item	(A)

Respondent Hours Per Occurrence	(B)

Number of Occurrences Per Respondent Per Year	(C)

Person Hours Per Respondent Per Year (C=AxB)	(D)

Number of Respondents Per Year	(E)

Technical Hours Per Year (E=CxD)	(F)

Management Hours Per Year (F=Ex0.05)	(G)

Clerical Hours Per Year (G=Ex0.1)	(H)

Total Hours Per Year (H=E+F+G)	(I)

Total Cost Per Year

1	Applications	Not applicable	 	 	 	 	 	 	 	 

2	Surveys and Studies	Not applicable	 	 	 	 	 	 	 	 

3	Reporting Requirements	 	 	 	 	 	 	 	 	 

 	A.	Read and Understand Rule Requirements	40	1	40	0	0	0	0	0	$0.00 

 	B.	Required Activities	 	 	 	 	 	 	 	 	 

 	 	1) Initial performance tests and reports (PM, dioxins/furans,
opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0.00	0.00	0.00	$0.00 

 	 	2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)	 	 	 	 
 	 	 	 	 

 	 	 	a) Installation of CEM units	225	1	225	0	0	0.00	0.00	0.00	$0.00


 	 	 	b) Initial demonstration	450	1	450	0	0	0.00	0	0.00	$0.00 

 	 	3) Annual performance tests and test reports (PM, dioxins/furans,
opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	1	775	38.75	77.50	891.25
$83,819.74 

 	 	4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)	 	 	 	 
 	 	 	 	 

 	 	 	a) RATA audit (one per year)	350	1.86	651	1	651	32.55	65.10
748.65	$70,408.58 

 	 	 	b) RAA audit (three per year)	130	5.58	725.40	1	725.40	36.27
72.54	834.21	$78,455.27 

 	 	 	c) Daily calibration and operation	1	678.90	678.90	1	678.90
33.95	67.89	780.74	$73,426.09 

 	C.	Create Information	Included in 3.B	 	 	 	 	 	 	 	 

 	D.	Gather Information	Included in 3.E	 	 	 	 	 	 	 	 

 	E.	Report Preparation	 	 	 	 	 	 	 	 	 

 	 	1) Plant startup	 	 	 	 	 	 	 	 	 

 	 	 	a) Preliminary and final material separation plans and siting
analysis	270	1	270	0	0	0	0	0	$0.00 

 	 	 	b) Public meeting and comment response	140	1	140	0	0	0	0	0
$0.00 

 	 	 	c) Notification of construction	2	1	2	0	0	0	0	0	$0.00 

 	 	 	d) Notification of startup	2	1	2	0	0	0	0	0	$0.00 

 	 	2)  Notification of initial performance tests	4	1	4	0	0	0	0	0
$0.00 

 	 	3)  Initial compliance reports	40	1	40	0	0	0	0	0	$0.00 

 	 	4)  Notification of CEMS demonstration	4	1	4	0	0	0	0	0	$0.00 

 	 	5)  Initial CEMS demonstration report	40	1	40	0	0	0	0	0	$0.00 

 	 	6)  Annual compliance reports	40	1.86	74.40	1	74.40	3.72	7.44
85.56	$8,046.69 

 	 	7)  Semi-annual excess emission reports	40	2	80	0.5	40	2	4.00	46
$4,326.18 

 	Subtotal - Reporting Requirements	 	 	 	 	 	 	 	3,386.41
$318,482.56

4	Recordkeeping Requirements	 	 	 	 	 	 	 	 	 

 	A.	Read Instructions	Included in 3.A	 	 	 	 	 	 	 	 

 	B.	Plan Activities	Included in 3.B	 	 	 	 	 	 	 	 

 	C.	Implement Activities	Included in 3.B	 	 	 	 	 	 	 	 

 	D.	Develop Record System	Not applicable	 	 	 	 	 	 	 	 

 	E.	Record information	 	 	 	 	 	 	 	 	 

 	 	1) Record startups, shutdowns, and malfunctions	4	47	188	1	188
9.40	18.80	216.20	$20,333.05 

 	 	2) Records of all emission rates, computations, tests	4	47	188	1
188	9.40	18.80	216.20	$20,333.05 

 	 	3) Records of employee review of operations manual	4	1	4	1	4	0.20
0.40	4.60	$432.62 

 	 	4) Record amount of sorbent used for Hg and dioxin/furan control	4
4	16	1	16	0.80	1.60	18.40	$1,730.47 

 	F.	Personnel Training	Not applicable	 	 	 	 	 	 	 	 

 	G.	Time for audits	Not applicable	 	 	 	 	 	 	 	 

 	Subtotal - Recordkeeping Requirements	 	 	 	 	 	 	 	455.40
$42,829.18

TOTAL LABOR BURDEN AND COST: 	 	 	 	 	 	 	 	3,842 (Rounded)
$361,312 (Rounded)



ASSUMPTIONS

Assumes four existing affected facilities at two plants.												

Assumes one additional new private facility/respondent will become
subject to the standard over the next three years.				

The number of respondents averaged over the three-year ICR cycle is
estimated to be 2 (Rounded).		

There are an average of 1.86 affected facilities (i.e., sources or
units) per respondent [4.33 facilities at 2.33 plants = 1.86 (Rounded)].

Relative accuracy test audits (RATA) occur once per year for each
affected facility (1 x 1.86 = 1.86).				

Relative accuracy audits (RAA) occur three times per year for each
affected facility (3 x 1.86 = 5.58).

Daily calibration and operation data occurs daily (365 x 1.86 = 678.90).

Costs are based on the following hourly rates: technical at $97.59,
management at $114.77, and clerical at $48.26.

RATA audits are performed for one of the four quarterly audits.  RAA
tests are performed for three of the four quarterly audits.  Audits of
the diluent monitor (O2 or CO2) are not required because tests on SO2
and CO monitors will incorporate the use of the diluent monitor.

Assumes 47 weeks of operation (90 percent availability) per year per
facility.

Assumes one source has a facility with excess emissions and must submit
two semiannual reports.

Table 2.  Annual Agency Burden for the NSPS for Small Municipal Waste
Combustors (40 CFR part 60, subpart AAAA) (Renewal)

 	(A)	(B)	(C)	(D)	(E)	(F)	(G)

Burden Item	Number of Occurrences Per Year	EPA Person Hours Per
Occurrence	Tech Hours Per Year (C=AxB)	Management Hours Per Year
(D=Cx0.05)	Clerical Hours Per Year (E=Cx0.1)	Total Hours Per Year
(F=C+D+E)	EPA Cost Per Year

1	Applications	not applicable	 	 	 	 	 	 

2	Read and Understand Rule Requirements	0	40	0	0	0	0	$0 

 	A.	Create Information	0	0	0	0	0	0	$0 

 	B.	Gather Information	0	0	0	0	0	0	$0 

 	C.	Report Reviews	 	 	 	 	 	 	 

 	 	1) Review preliminary and final material separation plans and
siting analysis	1	8	8	0.40	0.80	9.20	$408.42 

 	 	2) Review notification of construction	1	2	2	0.10	0.20	2.30
$102.10 

 	 	3) Review notification of startup	1	2	2	0.10	0.20	2.30	$102.10 

 	 	4) Review notification of initial performance test	1	8	8	0.40	0.80
9.20	$408.42 

 	 	5) Review notification of initial CEMS demonstration	1	4	4	0.20
0.40	4.60	$204.21 

 	 	6) Review initial performance test report	1	40	40	2	4	46	$2,042.08


 	 	7) Review initial CEMS demonstration report	1	40	40	2	4	46
$2,042.08 

 	 	8) Review annual compliance report	2.33	70	163.10	8.16	16.31
187.57	$8,326.58 

 	 	9) Review semi-annual excess emission report	2	16	32	1.60	3.20
36.80	$1,633.66 

 	D.	Prepare annual summary report	1	200	200	10	20	230	$10,210.40 

TOTAL ANNUAL BURDEN AND COST:	 	 	 	 	 	574 (Rounded)	$25,480
(Rounded)

		

ASSUMPTIONS

Agency estimated labor rates are: technical at $45.52, management at
$61.36, clerical at $24.64.

Assumes four affected facilities at two plants.

Assumes one additional facility/respondent over the next three years.

The number of respondents averaged over the three-year ICR cycle is
estimated to be 2.33.

Assumes one source has a facility with excess emissions and must submit
two semiannual reports.

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