SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for Incinerators (40 CFR Part 60, Subpart E) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Incinerators (40 CFR Part 60, Subpart E), EPA ICR Number
1058.10, OMB Control Number 2060-0040

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Incinerators were
promulgated on July 25, 1977.  These standards apply to incinerators
that charge more than 45 metric tons per day (50 tons per day) of solid
waste for the purpose of reducing the volume of the waste after
promulgation of NSPS.  Solid waste is defined as refuse that is more
than 50 percent municipal wastes.  This information is being collected
to assure compliance with 40 CFR part 60, subpart E.

Owners or operators of the affected facilities described must make
one-time-only notifications including: (1) notification of any physical
or operational change to an existing facility which may increase the
regulated pollutant emission rate; (2) notification of the initial
performance test, including information necessary to determine the
conditions of the performance test; and (3) performance test
measurements and results.  Owners or operators are also required to
maintain records of the occurrence and duration of any startup,
shutdown, or malfunction (SSM) in the operation of an affected facility,
or any period during which the monitoring system is inoperative. 
Monitoring requirements specific to NSPS, subpart E, provides
information on daily charging rates and the hours of operation.

Approximately 82 sources are currently subject to the regulation.  It is
estimated that no new sources will become subject to 40 CFR part 60,
subpart E, in the next three years, as new sources will be subject to
either 40 CFR part 60, subpart Eb, or 40 CFR part 60, subpart AAAA. 
Large Municipal Waste Combustors (MWC) with a capacity greater than 250
tons per day that are constructed, modified, or reconstructed after
September 20, 1994 are subject to 40 CFR part 60, subpart Eb.  Small
MWCs with capacities of 35 to 250 tons per day of municipal solid waste
that commenced construction after August 30, 1999, or commenced
reconstruction or modification after June 6, 2001, are subject to 40 CFR
part 60, subpart AAAA.  While it is not anticipated that new sources
will be subject to reporting requirements, existing sources will still
need to comply with the recordkeeping requirements of the regulations. 
The average annual labor cost to industry over the next three years of
this Information Collection Request (ICR) is estimated to be $793,858. 
Annual operation and maintenance costs are estimated to be $205,000, and
there are no capital/startup costs associated with this ICR renewal.

Any owner or operator subject to the provisions of this part will
maintain a file of these measurements, and retain the file for at least
two 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 United States Environmental Protection Agency (EPA)
regional office.

The active (previous) ICR had the following Terms of Clearance (TOC): 

The burden and cost assumptions and calculations for the respondents and
the agency should be updated in the next renewal.

EPA has addressed the TOC by updating respondent assumptions using
September 2009 labor rates from the United States Department of Labor,
Bureau of Labor Statistics.  Agency assumptions were updated using the
Office of Personnel Management (OPM), 2010 General Schedule for Agency
labor.  Respondent and Agency cost assumptions are provided in Sections
6(b)(i) and 6(c) of this document. 

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost - NSPS for Incinerators (40 CFR part
60, subpart E) (Renewal).  The burden to the “Federal government” is
attributed entirely to work performed by federal employees or government
contractors; this burden may be found below in Table 2: Average Annual
EPA Burden - NSPS for Incinerators (40 CFR part 60, subpart E)
(Renewal).  

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, particulate matter emissions from
municipal incinerators cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS were promulgated for this source category at 40 CFR
part 60, subpart E.

2(b)  Practical Utility/Users of the Data

The control of emissions of particulate matter from municipal
incinerators requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of particulate matter from municipal incinerators are the
result of operation of the affected facilities.  The subject standards
are achieved by the reduction of particulate matter emissions using
control technology and leak detection and repair (LDAR) procedures.  The
notifications required in the applicable regulations 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 leaks are being detected and
repaired and the regulations are being met.

Performance test reports are needed as these are the Agency's records of
a source's initial capability to comply with the emission standards, and
serve as a record of the operating conditions under which compliance was
achieved.  The information generated by the monitoring, recordkeeping
and reporting requirements described in this ICR is used by the Agency
to ensure that facilities that are affected by the NSPS continue to
operate the control equipment in compliance with the regulation. 
Adequate monitoring, recordkeeping, and reporting are necessary to
ensure compliance with the applicable regulations, as required by the
Clean Air Act.  The information collected from recordkeeping and
reporting requirements is also used for targeting inspections, and is of
sufficient quality to be used as evidence in court.

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

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

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 their own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or a local agency can be sent to the Administrator in lieu of the
report 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 on July 30, 2009 (74 FR 38004). 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered during a previous renewal of this ICR. 
The primary source of information as reported by industry, in compliance
with the recordkeeping and reporting provisions in the standard, was the
Air Facility System (AFS) which is operated and maintained by the EPA
Office of Compliance.  AFS is the EPA database for the collection,
maintenance, and retrieval of all compliance data.  The growth rate for
the industry was based on our consultations with the Agency’s internal
industry experts.  Approximately 82 respondents would 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 likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR 1320.5(d)(2).

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

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
incinerators.  The United States Standard Industrial Classification
(SIC) code for the respondents affected by the standards, which
corresponds to the North American Industry Classification System (NAICS)
codes, are listed below for source category description.

Standard (40 CFR part 60, subpart E)	SIC Codes	NAICS Codes

Air and Water Resource and Solid Waste Management	9511	924110

Refuse Systems (hazardous waste treatment and disposal)	4953	562211

Refuse Systems (material recovery facilities)	4953	562920

Refuse Systems (other nonhazardous waste treatment and disposal)	4953
562219

Refuse Systems (solid waste combustors and incinerators)	4953	562213

Refuse Systems (solid waste landfills)	4953	562212



Data from the year 2000 inventory of large municipal waste combustors
(MWCs) and the year 2001 inventory of small MWCs indicated that on
average 75.5 percent of large and small MWCs are publicly owned, while
the remaining 24.5 percent are privately owned.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR 1320.5(d)(2).

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by New
Source Performance Standards, for Incinerators (40 CFR part 60, subpart
E).

A source must make the following reports:

Notification Reports	Standard Citation by Section

Notification and application of construction or modification.	60.7(a)(1)

Notification of anticipated date of startup.	60.7(a)(2)

Notification of actual startup.	60.7(a)(3)

Notification of physical or operational change which may increase the
regulated pollutant emission rate.	60.7(a)(4)

Notification of initial performance tests.	60.8(d), 60.52(a), and
60.54(a)

Initial performance test results, to determine the conditions of the
performance test, and performance test measurements and results.
60.8(d), 60.52(a), and 60.54(a)



A source must keep the following records:

Recordkeeping

Records of the occurrence and duration of any startup, shutdown, or
malfunction in operation of an affected facility.	60.7(b)

Records of malfunctions of the air pollution control equipment.	60.7(b)

Records of periods when the system is inoperative.	60.7(b)

Records of daily charging rates and hours of operation.	60.53(a)

Records of the initial performance test and performance test
measurements and results.	60.8(c), 60.52(a) and 60.54(a)

Maintain records for two years	60.7(f)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., gases which contain
particulate matter.  Although personnel at the source still need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.  In
addition, some regulatory agencies are setting up electronic reporting
systems to allow sources to report electronically which is reducing the
reporting burden.  However, electronic reporting systems are still not
widely used by the regulatory agencies.  It is estimated that
approximately 10 percent of the respondents use electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate compliance monitoring system
(CMS) for opacity, or for pressure drop and liquid supply pressure for
wet scrubber.

Perform initial performance test, Reference Method 1, 2, 3B, and 5 test,
and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the source still need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.

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.



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operated.  Performance test reports are used by
the Agency to discern a source’s initial capability to comply with the
emission standard and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.  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 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 the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices
and EPA headquarters.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or
operator for two years.

5(c)  Small Entity Flexibility

A majority of the affected facilities are large entities (e.g., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.

	Data from a 1996 inventory of municipal waste combustors indicated that
21 percent of affected sources were located in an area with less than
50,000 people.  This was the basis of our estimate for affected small
businesses for this ICR renewal.

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 - NSPS for Incinerators (40 CFR part 60, subpart E) (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 8,393
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the 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	$114.49 ($54.52 + 110%)   

Technical	$98.20 ($46.76 + 110%)

Clerical	$48.53 ($23.11 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2009, “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 types of industry cost associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time cost when a facility
becomes subject to the regulation.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitors and other costs
such as photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents 	(D)

Total Capital/Startup Cost,

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Particulate Matter	$5,000	0	0	$2,500	82	$205,000



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 $205,000.  This is the total of column G.  

The total respondent costs have been calculated as the addition of the
capital/startup costs, and the annual operation and maintenance costs. 
The average annual cost for capital/startup and operation and
maintenance cost to industry over the next three years of the ICR is
estimated to be $205,000.  

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 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 $0.  This cost is based on the average hourly labor rate
as follows:

Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2010
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: Average Annual EPA Burden - NSPS for
Incinerators, (40 CFR part 60, subpart E) (Renewal).

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

Based on our research for this ICR, approximately 82 existing sources
are currently subject to the standard.  It is estimated that no expected
additional sources per year will become subject to the standard in the
next three years.

Number of respondents is calculated using the following table which
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	82	0	0	82

2	0	82	0	0	82

3	0	82	0	0	82

Average	0	82	0	0	82

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 82.  The number of respondents is calculated using the
following table which addresses each of the three years covered by this
ICR.

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

Notification reports	0	0	0	0

Compliance reports	0	0	0	0

Recordkeeping:





-  Records of SSM, emissions monitoring system, and initial performance
test results	0	0	82	82

-  Records of daily charging rates and hours of operation	0	0	82	82

Total



164



The number of Total Annual Responses is 164.  The total annual labor
costs are $793,858.  Details regarding these estimates may be found
below in Table 1: Annual Respondent Burden and Cost - NSPS for
Incinerators (40 CFR part 60, subpart E) (Renewal).  Note that the total
annual capital and O&M costs to the regulated entity are $205,000. 
These costs are detailed in Section 6(b)(iii), Capital/Startup vs.
Operation and Maintenance (O&M) Costs.

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

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information are estimated to average 51
hours per response.

6(f)  Reasons for Change in Burden

There are no changes to the labor hours for the respondents in this ICR
as compared to the previous ICR.  This is due to two considerations: 1)
the regulations have not changed over the past three years and are not
anticipated to change over the next three years; and 2) the growth rate
for the respondents is very low, negative or non-existent.  

There is, however, an increase in respondent labor costs due to labor
rate increases from 2003 to the most recent available labor rate data.  

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 51 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 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-2009-0526.  An electronic version of the public docket is
available at http://www.regulations.gov/ which 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, N.W., Washington, D.C.  The
EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays.  The telephone
number for the Reading Room is (202) 566-1744, and the telephone number
for the 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, N.W., Washington, D.C. 20503, Attention:
Desk Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0526 and OMB Control Number 2060-0040 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 - NSPS for Incinerators (40
CFR Part 60, Subpart E) (Renewal).

	Burden item	

(A)

Technical Person-hours per occurrence	

(B)

No. of occurrences per respondent per year	

(C)

Technical Person-hours per respondent per year

(C=AxB)	

(D)

Respondents per year 	

(E)

Technical person-hours per year

(E=CxD)	

(F)

Management person-hours per year

(Ex0.05)	

(G)

Clerical person-hours per year

(Ex0.1)	

(H)

Total Cost Per Year  a



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting Requirements	

	

	

	

	

	

	

	





A. Read instructions	

1	

1	

1	

0b,c	

0	

0	

0	

$0



B. Required activities	

	

	

	

	

	

	

	





Initial performance test d	

200	

1	

200	

0b,c	

0	

0	

0	

$0



C. Create information on performance test	

Included in 3B 	

	

	

	

	

	

	





D. Gather existing information	

Included in 3E	

	

	

	

	

	

	





E.  Write Report	

	

	

	

	

	

	

	





Notification of construction/reconstruction	

2	

1	

2	

0b,c	

0	

0	

0	

$0



Notification of actual startup	

2	

1	

2	

0b,c	

0	

0	

0	

$0



Notification of physical and operational changes which may increase
emission rates of any regulated pollutants	

2	

1	

2	

0	

0	

0	

0	

$0



Notification of initial performance test 	

2	

1	

2	

0b,c	

0	

0	

0	

$0



Report of initial performance test results	

4	

1 	

4	

0b,c	

0	

0	

0	

$0



Compliance status reports e	

4	

1	

4	

0	

0	

0	

0	

$0

Subtotal Reporting



	0	$0



4.  Recordkeeping Requirements	

	

	

	

	

	

	

	





A.  Read instructions	

Included in 4E	

	

	

	

	

	

	





B.  Plan activities	

Included in 4E	

	

	

	

	

	

	





C.  Implement activities	

Included in 4E	

	

	

	

	

	

	





D.  Develop record system	

N/A	

	

	

	

	

	

	





E.  Time to enter information	

	

	

	

	

	

	

	





a. Record of occurrence and duration of startup, shutdown, or
malfunction, emissions monitoring system, and initial performance test
results.	

1.5	

1	

1.5	

82f	

123	

6.15	

12.3	

$13,379.63



b.  Records of daily charging g rates and hours of operation	

.25

	

350	

87.5	

82f	

7,175	

358.75	

717.5	

$780,478.56



F.  Time to train personnel	

N/A	

	

	

	

	

	

	





G.  Time for audits	

N/A	

	

	

	

	

	

	





Subtotal Recordkeeping	

	

	

	

	

8,392.7	

$793,858.19



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

8,393

(rounded)	

$793,858 (rounded)



Assumptions:

a  This ICR uses the following labor rates: $114.49 per hour for
Executive, Administrative, and Managerial labor; $98.2 per hour for
Technical labor, and $48.53 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, September 2009, ”Table 2. Civilian workers, by
Occupational and Industry group.”

b  Assume that there will be no new, modified or reconstructed facility
constructed for the next three years.

c  Assume that this is a one-time-only cost.

d  Assume it takes 60 technical person-hours for pretests/test
preparation, 60 hours for testing, and 80 hours for analysis and report
preparation.

e  This rule does not require semiannual reporting, just recordkeeping.

f  Assume that there are 82 sources subject to this rule.

g  Assume it will take .25 hours per day for 350 days to record daily
charging rates.

Table 2:  Average Annual EPA Burden - NSPS for Incinerators (40 CFR
Part 60, Subpart E) (Renewal) 

	Burden Item	

(A)

Technical Person Hours Per Occurrence	

(B)

Number of Occurrences Per Year

	

(C)

Technical Person Hours Per Plant Per Year

(C=AxB)	

(D)

Plants Per Year	

(E)

Technical Hours Per Year

(E=CxD)	

(F)

Management Hours Per Year

(F=0.05xE)	

(G)

Clerical Hours Per Year

(G=0.1xE)	

(H)

Total a Costs Per Year



Report Review	

	

	

	

	

	

	

	





Notification of construction/ reconstruction	

2	

1	

2	

0b,c	

0	

0	

0	

$0



Notification of actual startup	

2	

1	

2	

0b,c	

0	

0	

0	

$0



Notification of physical and operational changes which may increase
emission rates of any regulated pollutant	

2	

1	

2	

0	

0	

0	

0	

$0



Compliance status report e	

4	

1	

4	

0	

0	

0	

0	

$0



Test results e	

8	

1	

8	

0	

0	

0	

0	

$0



Audit and review facility records	

6	

1	

6	

0	

0	

0	

0	

$0



TOTAL LABOR BURDEN and COST (rounded)	

	

0	

$0



Assumptions:

a   This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 + 60%), $46.21
for Technical (GS-12, Step 1, $28.88 + 60%) and $25.01 Clerical (GS-6,
Step 3, $15.63 + 60%).  These rates are from the Office of Personnel
Management (OPM) (2010 General Schedule( which excludes locality rates
of pay.

b  Assume that there will be one new, modified or reconstructed facility
constructed over the next three years.

c  Assume that this is a one-time-only cost.

d  This rule does not require semiannual reporting, just recordkeeping.

e  Assume that it will take eight hours to review test results.

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