SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for Emission Guidelines and Compliance Times for Small Municipal
Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR
Part 60, Subpart BBBB) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Emission Guidelines and Compliance Times for Small Municipal
Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR
Part 60, Subpart BBBB) (Renewal), EPA ICR Number 1901.04, OMB Control
Number 2060-0424

1(b)  Short Characterization/Abstract

The New Source Performance Standards (  SEQ CHAPTER \h \r 1 NSPS) for
Emission Guidelines and Compliance Times for Small Municipal Waste
Combustion (MWC) Units Constructed on or Before August 30, 1999,
(“Emission Guidelines”), were originally promulgated in December
1995, but were vacated by the Federal Court in March 1997.  The Emission
Guidelines were re-proposed on August 30, 1999, and promulgated on
December 6, 2000 (65 FR76378).  The Emission Guidelines regulate
organics (dioxin/furans), metals (cadmium, lead, mercury, and
particulate matter), and acid gases (hydrogen chloride, sulfur dioxide,
and nitrogen oxides).

	

	The Emission Guidelines contain monitoring, reporting, and
recordkeeping requirements that are to be included in state plans.  This
Information Collection Request (ICR) identifies the burden to
respondents (i.e., small MWCs) that will be imposed by state plans
developed to implement the Emission Guidelines.  Respondents are owners
or operators of existing small MWC units.  Small MWC units are units
with capacities to combust greater than 35 tons per day and less than
250 tons per day of municipal solid waste.

	

	In general, all Emission Guidelines standards require initial reports,
semiannual reports and annual reports.  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.  Owners or operators subject to the Emission Guidelines are
required to maintain files for at least five years.

	

Approximately 54 sources located at 23 plants are currently subject to
the Emission Guidelines.  Since the Emission Guidelines only apply to
sources that commenced construction on or before August 30, 1999, no
additional MWC units will become subject to the standard over the next
three years.  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(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; . . ..

2(b)  Practical Utility/Users of the Data

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

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

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

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 (70 FR citation 55368) on
September 21, 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) recently
developed a facility and emissions index for small municipal waste
combustors.  The industry voluntarily submitted data as part of a NSPS
compliance evaluation.  As a result, this information is current.  We
are able to rely on the information from the facility and emissions
index to obtain 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

  SEQ CHAPTER \h \r 1 The respondents to the recordkeeping and reporting
requirements are small municipal waste combustors.  The United States
Standard Industrial Classification (SIC) codes and corresponding North
American Industry Classification System (NAICS) codes for the
respondents affected by the standards are shown in the table below.

  SEQ CHAPTER \h \r 1 Regulation	SIC Codes	NAICS Codes

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

40 CFR part 60, subpart BBBB	4953 Refuse System	562213 Solid Waste
Combustors and Incinerators



4(b)  Information Requested

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
NSPS for Emission Guidelines and Compliance Times for Small Municipal
Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR
part 60, subpart BBBB) (Renewal).

A source must make the following reports:

  SEQ CHAPTER \h \r 1 Reports for Existing Small Municipal Waste
Combustion Units (40 CFR Part 60, Subpart BBBB)

Construction/reconstruction	60.7(a)(1)

Notification of completion of each increment of progress	60.1585

Initial report	60.8 (a) & (d), 60.1860, 60.1875

Annual Report	60.1680, 60.1880

Actual startup	60.7(a)(3), 

Semiannual reports for any emission or parameter that doesn’t meet
limits	60.1680, 60.1890, 60.1895, 60.1900

Demonstration of continuous monitoring system	60.7(a)(5)

Physical or operational change	60.7(a)(4)



A source must keep the following records:

  SEQ CHAPTER \h \r 1 Recordkeeping for Existing Small Municipal Waste
Combustion Units (40 CFR Part 60, Subpart BBBB)

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	60.7(b)

Emission test results and other data needed to determine emissions.
60.1830, 60.1835, 60.1845

Operator training & certification	60.1830, 60.1835, 60.1840

Record for MWCs using activated carbon	60.1830, 60.1835, 60.1855

Records for continuously monitored pollutants or parameters.	60.1830,
60.1850

Records are required to be retained for 5 Years.  All five years of
records must be retained at the facility.	60.1835



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

  SEQ CHAPTER \h \r 1 Respondent Activities

Read instructions.

 Install, calibrate, maintain, and operate CEMS for SO2, N0x, opacity,
CO, CO2 & O2.

Perform initial performance test and reports (PM, dioxin/furans,
opacity, fugitives, HCL, Cd, Pb, Hg), and repeat performance tests if
necessary.

Write & submit 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.

Perform quarterly Appendix F audits of CEMS (SO2, N0x, CO)

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

  SEQ CHAPTER \h \r 1 Some of the small MWC units potentially affected
by the Emission Guidelines 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 small MWC
units where the aggregate plant capacity is less than 250 tpd can skip
annual tests for 2 year periods for certain pollutants if they have
demonstrated compliance for three annual tests in a row.  In addition to
this 3-year testing option, less frequent dioxin/furan testing is
possible if all 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 1: Annual Respondent Burden and
Cost of Recordkeeping and Reporting Requirements NSPS for Emission
Guidelines and Compliance Times for Small Municipal Waste Combustion
Units Constructed on or Before August 30, 1999 (40 CFR part 60, subpart
BBBB) (Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of 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
100,854 hours.  These hours are based on Agency studies and background
documents from the development of the regulation, Agency knowledge and
experience with the NSPS program, the previously approved ICR, and any
comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$100.99 ($48.09 + 110%)

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 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 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 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 Source (i.e., Affected Facility)	(C)

Number of New Sources 	(D)

Total Capital/Startup Cost,

(B X C)	(E)

Annual O&M Costs for One Source	(F)

Number of Sources 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	$0	$19,200	54	$1,036,800



 	

The total capital/startup costs for this ICR are $0.  This is the total
of column D in the above table.  

The total operation and maintenance (O&M) costs for this ICR are
$1,036,800.  This is the total of column G.

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 $1,036,800.  

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 $108,581.

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“. Details upon which this estimate is based appear
below in Table 2: Annual Agency Burden for the NSPS for Emission
Guidelines and Compliance Times for Small Municipal Waste Combustion
Units Constructed on or Before August 30, 1999 (40 CFR part 60, subpart
BBBB).		

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 23 existing respondents will be subject to the
standard.  It is estimated that no additional respondents will become
subject to this standard over the next three years.  The overall average
number of respondents, as shown in the table below is 23 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	23	0	0	23

2	0	23	0	0	23

3	0	23	0	0	23

Average	0	23	0	0	23



As shown above, the average Number of Respondents over the three-year
period of this ICR is 23.  

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

Plant Startup (Plant Control Plan, notifications, etc.)	0	5	0	0

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

Annual Reports	23	2.35	0	54.05

Semiannual Excess Emission Reports	2.3	2	0	4.6



	Total	59 (Rounded)



The number of Total Annual Responses is 59.  

The total annual labor costs are $8,541,926.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost of Recordkeeping and Reporting Requirements NSPS for Emission
Guidelines and Compliance Times for Small Municipal Waste Combustion
Units Constructed on or Before August 30, 1999 (40 CFR part 60, subpart
BBBB) (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 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

The total annual labor costs are $8,541,926.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost of Recordkeeping and Reporting Requirements NSPS for Emission
Guidelines and Compliance Times for Small Municipal Waste Combustion
Units Constructed on or Before August 30, 1999 (40 CFR part 60, subpart
BBBB) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 1,709 hours per
response.

The total annual capital/startup and O&M costs to the regulated entity
are $1,036,800. 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 2,748 labor hours at a cost of $108,581.  See below
Table 2: Annual Agency Burden for the NSPS for Emission Guidelines and
Compliance Times for Small Municipal Waste Combustion Units Constructed
on or Before August 30, 1999 (40 CFR part 60, subpart BBBB) (Renewal).

6(f)  Reasons for Change in Burden

There is no change to the hours in the total estimated burden currently
identified in the OMB Inventory of Approved ICR Burdens.  Since there
are no changes in the regulatory requirements and there is no
significant industry growth, the labor hours and cost figures used in
the previous ICR are also used in this ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 1,709 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-2009-0447, which is available for public viewing at the
Enforcement and Compliance Docket and Information Center in the EPA
Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., 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 Office of Enforcement and Compliance
(OECA) Docket is (202) 566-1752.  An electronic version of the public
docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket.  Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select ”search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0447 and OMB Control Number 2060-0424 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 Recordkeeping and
Reporting Requirements for the NSPS for Emission Guidelines and
Compliance Times for Small Municipal Waste Combustion Units Constructed
on or Before August 30, 1999 (40 CFR part 60, subpart BBBB) (Renewal)

Burden Item	(A)

Respondent Hours Per Occurrence	(B)

Number of Occurrences Per Respondent Per Year	(C)

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 Costs 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 

 	B.	Required Activities	 	 	 	 	 	 	 	 	 

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

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

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

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

 	 	3) Annual performance tests and test reports (PM, dioxins/furans,
opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	23	17,825	891.25	1,782.50
20,498.75	$1,736,163.91

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

 	 	 	a)  RATA audit (one per year)	350	2.3	805	23	18,515	925.75
1,851.50	21,292.25	$1,803,370.26

 	 	 	b)  RAA audit (three per year)	130	6.9	897	23	20,631	1031.55
2,063.10	23,725.65	$2,009,469.72

 	 	 	c)  Daily calibration and operation	1	840	840	23	19,320	966
1,932	22,218	$1,881,777.66

 	C.	Create Information	Included in 3.B	 	 	 	 	 	 	 	 

 	D.	Gather Information	Included in 3.E	 	 	 	 	 	 	 	 

 	E.	Report Preparation	 	 	 	 	0	0	0	0	 

 	 	1) Plant startup	 	 	 	 	 	 	 	 	 

 	 	 	a)  Plant Control Plan	40	1	40	0	0	0	0	0	$0 

 	 	 	b)  Notification of Contract Awards	4	1	4	0	0	0	0	0	$0 

 	 	 	c)  Notification of on-site construction start	4	1	4	0	0	0	0	0
$0 

 	 	 	d)  Notification of construction completion	4	1	4	0	0	0	0	0	$0 

 	 	 	e)  Notification of final completion	4	1	4	0	0	0	0	0	$0 

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

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

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

 	 	5) Initial CEMS demonstration report	90	1	90	0	0	0	0	0	$0 

 	 	6) Annual compliance reports	40	2.3	92	23	2,116	105.8	211.60
2,433.40	$206,099.46

 	 	7) Semiannual excess emission reports	40	2	80	2.3	184	9.2	18.40
211.60	$17,921.69

	Subtotal - Reporting Requirements







90379.65	$7,654,802.70

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	23	4,324
216.2	432.40	4,972.60	$421,159.76

 	 	2) Records of all emission rates, computations, tests	4	47	188	23
4,324	216.2	432.40	4,972.60	$421,159.76

 	 	3) Records of employee review of operations manual	4	1	4	23	92	4.6
9.20	105.80	$8,960.85

 	 	4) Record amount of sorbent used for Hg and dioxin/furan control	4
4	16	23	368	18.4	36.80	423.20	$35,843.38

 	F.	Personnel Training	Not applicable	 	 	 	 	 	 	 	 

 	G.	Time for audits	Not applicable	 	 	 	 	 	 	 	 

	Subtotal – Recordkeeping Requirements







10474.20	$887,123.75

TOTAL LABOR BURDEN AND COST: 	100,854	$8,541,926 

 	Rounded	Rounded

TABLE 1 ASSUMPTIONS

Assumes an average of 2.3 affected facilities (i.e., sources or units)
per respondent [53 facilities at 23 plants; 53/23 = 2.3 (Rounded)].	

Relative accuracy test audits (RATA) occur once per year for each
affected facility (1 x 2.3 = 2.3).					

Relative accuracy audits (RAA) occur three times per year for each
affected facility (3 x 2.3 = 6.9).						

Daily calibration and operation data occurs daily [365 x 2.3 = 840
(Rounded)].			

No additional facilities will become subject to the standard over the
next three years.		

Costs are based on the following hourly rates: technical at $87.97,
management at $100.99, and clerical at $43.81. 				

RATA 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 10 percent of sources (2.3) have affected facilities with excess
emissions and must submit two semiannual reports.

Table 2.  Annual Agency Burden for the NSPS for Emission Guidelines and
Compliance Times for Small Municipal Waste Combustion Units Constructed
on or Before August 30, 1999 (40 CFR part 60, subpart BBBB) (Renewal)

Burden Item	 (A) 

Number of Occurrences Per Year	(B)

EPA Hours Per Occurrence	(C)

Tech Hours Per Year (C=AxB)	(D)

Management Hours Per Year (D=Cx0.05)	(E)

Clerical Hours Per Year (E=Cx0.1)	(F)

Total Hours Per Year (F=C+D+E)	(G)

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	0	0	0	0	0	0	$0 

 	 	1) Review preliminary and final material separation plans and
siting analysis	0	8	0	0	0	0	$0 

 	 	2) Review notification of construction	0	2	0	0	0	0	$0 

 	 	3) Review notification of startup	0	2	0	0	0	0	$0 

 	 	4) Review notification of initial performance test	0	8	0	0	0	0	$0 

 	 	5) Review notification of initial CEMS demonstration	0	4	0	0	0	0
$0 

 	 	6) Review initial performance test report	0	40	0	0	0	0	$0 

 	 	7) Review initial CEMS demonstration report	0	40	0	0	0	0	$0 

 	 	8) Review annual compliance report	23	92	2,116	105.80	211.60
2,433.40	$96,110.52

 	 	9) Review semi-annual excess emission report	4.60	16	73.60	3.68
7.36	84.64	$3,365.14

 	D.	Prepare annual summary report	1	200	200	10	20	230	$9,104.96

TOTAL ANNUAL BURDEN AND COST:	 	 	 	 	 	2,748 (Rounded)	$108,581
(Rounded)



TABLE 2 ASSUMPTIONS

Agency estimated labor rates are: technical at $42.45, management at
$57.20, clerical at $22.96.	

Assumes 53 affected units at 23 plants.	

Assumes submission of semiannual excess emission reports will be
required for 10 percent of units (2.3); (2 x 2.3 = 4.6).				

Assumes four hours to review the annual compliance report for each plant
(4 x 23 = 92).	

No additional sources will become subject to the standard over the next
three years.



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