SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Commercial and Industrial Solid Waste Incineration Units (40
CFR Part 60, Subpart CCCC) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NSPS for Commercial and Industrial Solid Waste Incineration Units (40
CFR Part 60, Subpart CCCC) (Renewal), EPA ICR Number 1926.05, OMB
Control Number 2060-0450

	1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) for Commercial and
Industrial Solid Waste Incineration Units (CISWI) were proposed on
November 30, 1999, and promulgated on December 1, 2000.  This standard
applies to solid waste incinerators as defined at 40 CFR, part 60,
subpart CCCC.

	Respondents are owners or operators of solid waste incinerators.  This
standard applies to new stationary sources, that is, incineration units
that meet either of the two criteria: 1) sources whose construction
begins after the NSPS is proposed, which is November 30, 1999; or 2)
sources that are reconstructed or modified on or after June 1, 2001. 
The standards apply to the owner or operator of a combustion device that
combusts commercial and industrial waste.  Commercial and industrial
waste is a solid waste combusted in an enclosed device using controlled
flame combustion without energy recovery, which is a distinct operating
unit of any commercial or industrial facility, including field-erected,
modular, and custom-built incineration units operating with starved or
excess air, or solid waste combusted in an air curtain incinerator
without energy recovery that is a distinct operating unit of any
commercial or industrial facility.

	The annual performance testing will ensure on an ongoing basis that the
air pollution control device is operating properly and its performance
has not deteriorated.  To minimize the burden of the annual performance
testing, the rule only requires that the owner or operator test for
particulate matter (PM), hydrogen chloride (HCl), and opacity.  Annual
performance testing is not required for dioxins/furans, cadmium (Cd),
carbon monoxide (CO), lead (Pb), mercury (Hg), nitrogen oxides (NO 
ADVANCE \d 3 x  ADVANCE \u 3 ), and sulfur dioxide (SO  ADVANCE \d 3 2 
ADVANCE \u 3 ).  This significantly reduces the testing costs while
still providing the EPA with sufficient data to adequately assess
compliance.  In addition, the rule allows the owner or operator to skip
two annual tests for a pollutant if all performance tests over the
previous three years show compliance with the emission limit.  During
the initial performance test (for PM, dioxins/furans, opacity, HCl, Cd,
Pb, Hg, CO, NO  ADVANCE \d 3 x  ADVANCE \u 3  and SO  ADVANCE \d 3 2 
ADVANCE \u 3 ), the owner or operator must establish maximum or minimum
values for each operating parameter.  Thereafter, the owner or operator
must conduct annual performance tests for PM, HCl, and opacity, and
continuously monitor the operating parameters.

	Owners or operators subject to the provisions of the subpart must
perform the following activities: conduct performance tests; monitor
operating parameters; prepare siting analysis; prepare waste management
plan, operator training and qualifications, one-time and periodic
reports, and the maintenance of records.  Reports are submitted
semiannually and annually.  These activities will enable EPA to
determine initial compliance with emission standards for the regulated
pollutants, monitor compliance with operating parameters, and ensure
that facilities conduct the proper planning and operator training. 
Owners or operators of CISWI units are required to keep records of
certain parameters and information for a period of five years.

	The standards include annual operator training requirements for
incinerator unit operators (rule requires at least one qualified
operator or supervisor per facility).  The annual training requirements
include annual refresher training to maintain operator qualifications
and an annual review of site-specific documentation.  The way in which
an incinerator is operated has a significant impact on the emissions
from that incinerator.  The annual operator training is essential to
ensure that the incinerator is being operated properly.  The rule
contains flexibility in the operator training by allowing the use of
state-approved training and qualification programs.

	Records and reports required by the NSPS for commercial and industrial
solid waste incineration units are necessary to enable EPA to identify
sources subject to the standards and to ensure that the standards are
being achieved.  Records and reports must be maintained at the facility
and/or submitted to EPA.  All reports are sent to the delegated state,
local, or tribal agency.  In the event that there is no such delegated
authority, the reports are sent directly to the U.S. Environmental
Protection Agency (EPA) regional office.

	The information collection requirements for the NSPS for Commercial and
Industrial Solid Waste Incineration Units are summarized in Section
4(b).

	Approximately 31 sources are currently subject to the regulation which
includes one new unit per year for the next three years.  All
respondents are owned by either business or other for-profit entities. 
The estimated labor cost of this ICR is $1,021,351.  

The burden to the “Affected Public” may be found below in Table 1:
Annual Industry Burden and Cost  - NSPS for Commercial and Industrial
Solid Waste Incineration Units (40 CFR part 60, subpart CCCC) (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: Annual EPA Burden - NSPS for
Commercial and Industrial Solid Waste Incineration Units (40 CFR part
60, subpart CCCC) (Renewal).

	The Office of Management and Budget (OMB) approved the current
Information Collection Request (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, emissions from commercial and
industrial solid waste 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 CCCC.

	2(b)  Practical Utility/Users of the Data

The information generated by monitoring, recordkeeping, and reporting
requirements described in this ICR is used by EPA to assure compliance
with the regulations which were 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
emission 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, if the continuous emission
monitoring systems are not required.  Performance test reports are
needed as these are the Agency 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 Agency or
delegated authority may also observe the performance test.

The notifications required by the regulation are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements and regulations.  The reviewing authority may then inspect
the source to check if the pollution devices are properly installed and
operated and if the facility complies with the regulatory standards.

The control of emissions of PM, HCl, or opacity from commercial and
industrial solid waste incineration units requires not only the
installation of properly designed equipment, but also the operation and
maintenance of that equipment.  Emissions of pollutants from commercial
and industrial solid waste incineration are the result of operation of
the affected facilities.  The subject standards are achieved by the
reduction of pollutant emissions using control technology and leak
detection and repair procedures.

	The semiannual reports are used for problem identification, as a check
on source operation and maintenance, and for compliance determinations. 
The information generated by the monitoring, recordkeeping and reporting
requirement described in this ICR is used by the Agency to ensure that
facilities affected by the NSPS continue to operate the control
equipment in compliance with the regulation.

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

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

subpart CCCC.

	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 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 primary source of information was the industry and EPA data
including an assessment by the Office of Air and Radiation.  Information
provided by the industry is retained in the EPA Air Facility System
(AFS) database 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.  Approximately 31 respondents are
currently subject to the regulation, including one new respondent in
each of the next three years. 

It should be noted that the industry trade associations and other
interested parties were provided an opportunity to comment on the burden
associated with the standard when it was proposed and the standard was
previously reviewed to determine the minimum information needed for
compliance purposes.  No major problems regarding the rule monitoring,
recordkeeping, or reporting were identified during the public comment
period.

	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 that emission limitations are met.  If the information
required by these standards were collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.  If the relevant information
is collected at less frequent intervals, the EPA would not be reasonably
assured that an affected facility owner or operator is in compliance
with the standards.

	

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

	These standards require affected facilities 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
with the part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

	3(f)  Confidentiality

	The required information has been determined not to be confidential. 
However, 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 these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 4 CFR part 1320, section 1320.5.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC and NAICS Codes

	The respondents to the recordkeeping and reporting requirements are
commercial and industrial solid waste incineration (CISWI) units.  The
United States Standard Industrial Classification (SIC) codes, which
correspond to the North American Industry Classification System (NAICS)
codes, can be found in the following table:

Standard	SIC Codes	NAICS Codes

Commercial and Industrial Solid Waste Incineration Units (40 CFR, part
60, subpart CCCC)



Manufacturers of chemicals and allied products	28	325

Manufacturers of electronic equipment	34	325

Manufacturers of wholesale trade, durable goods	36	421

Manufacturers of lumber and wood furniture	24, 25	321, 337



	4(b)  Information Requested 

	

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

		(i)  Data Items

	All data in this ICR that is recorded and/or reported is required by
New Source Performance Standards (NSPS) for Commercial and Industrial
Solid Waste Incineration (CISWI) Units (40 CFR part 60, subpart CCCC).

	A source must make the following reports:

Notification Reports

Notification of preconstruction (prior to commencing construction)
including anticipated date of initial startup	60.2190 

Notification of actual startup	60.2195

Notification of initial performance test	60.2200 

Annual report 	60.2205 and 60.2210

Emission limitation or operating limit deviation report	60.2215 and
60.2220

Qualified operator deviation notification	60.2225(a)(1)

Qualified operator deviation status report	60.2225(a)(2)

Qualified operator deviation notification of resumed operation
60.2225(b)

Status report for operator offsite for more than 2 weeks	60.2225(a)(2)



	A source must keep the following records:

Recordkeeping

Records of initial performance tests, annual performance tests, and any
subsequent performance tests.	60.2175(f)

Maintain records of days for which data on operating parameters have not
been obtained, including operating parameters not measured, reasons for
not measuring, and a description of corrective actions taken.	60.2175(c)

Maintain records of occurrence and duration of malfunction and the
corrective action taken.	60.2175(d)

Maintain records of days when deviation from operating limits have
occurred, and description of corrective actions taken.	60.2175(e)

Maintain records of all documentation produced for the siting analysis.
60.2175(g)

Maintain records of names of persons who have completed review of
site-specific information and incinerator operating procedures.
60.2175(h) and 60.2095(a)

Maintain records of names of persons who have completed the operator
training requirements.	60.2175(i)

Maintain records of names of phone and/or pager numbers of persons who
have met the operator qualification criteria.	60.2175(j)

Maintain records or calibration of monitoring devices.	60.2175(k)

Maintain records of equipment vendor specifications for the incinerator,
emission controls, and monitoring equipment.	60.2175(l)

Maintain records of daily log of quantity and types of wastes burned.
60.2175(n)

Records should be retained for five years.	60.2175



Electronic Reporting

	Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., leaks and spills of mercury. 
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 control devices for PM, HCl,
and opacity.

Perform initial performance test, Reference Method 1, 3A or 3B 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 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

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 AIRS Facility Subsystem (AFS).



	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 to 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
and annual emission inventory data for more than 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 five years.

	5(c)  Small Entity Flexibility

	A majority of the affected facilities are large entities (e.g., large
businesses).  The proposed NSPS and Emission Guidelines were intended to
cover CISWI units burning industrial solid waste, not combustors burning
municipal solid waste.  According to the final rule (65 FR 75348),
approximately 29 percent of companies that own affected facilities may
be small 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 to be
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.

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Industry Burden - NSPS
for Commercial and Industrial Solid Waste Incineration Units (CSWI) (40
CFR part 60, subpart CCCC) (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 11,246
(Total Labor Hours from Table 1) per year.  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 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 cost is a 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 1	(C)

Number of New Respondents 	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent 1	(F)

Number of Respondents with O&M	(G)

Total O&M

(E X F)

Wet Scrubber	$2,240	1	$2,240	$211	30	$6,330

	1  The capital/startup cost and O&M can be found in Table 1 under
column “Non-labor costs per occurrence” and “Total non-labor costs
per year”.

	The total capital/startup costs for this ICR are $2,240.  This is the
total of column D in the above table.  The total operation and
maintenance (O&M) costs for this ICR are $6,330.  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 $8,570.

	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 $9,521.

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

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

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

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

These rates are from the Office of Personnel Management (OPM) ”2006
General Schedule“ which excludes locality rates of pay.

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

	There are approximately 31 respondents that are currently subject to
the regulation.  Each respondent has one affected facility. 

Respondent Universe and Number of Responses Per Year

Regulation Citation by Section	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents Reporting	(D)

Number of Reports for Existing Sources	(F)

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

Total Annual Responses 

(AxB)+(CxD)+F

Preconstruction Report 	1	1	N/A	N/A	0	1

Startup Notification	1	1	N/A	N/A	0	1

Annual Report	N/A	N/A	30	1	0	30

Deviation Report	N/A	N/A	3	2	0	6

Qualified Operator Deviation Notification	N/A	N/A	3	1	0	3

Qualified Operator Report	N/A	N/A	3	2	0	6





	Total	47



	The number of total respondents is 31.  This represents the number of
existing sources plus the number of new sources averaged over the
three-year period (i.e., the total of the number of new respondents over
the three-year period divided by three years).

	The number of Total Annual Responses is 47.  This is the sum of column
E of the Respondent Universe and Number of Responses Per Year table
above.

	The Total Hours Requested is 11,246.  The total annual labor costs are
$1,021,351.  Details regarding these estimates may be found below in
Table 1: Annual Industry Burden and Cost - NSPS for Commercial and
Industrial Solid Waste Incineration Units (40 CFR part 60, subpart CCCC)
(Renewal).

 

	Note that the total annual capital and O&M costs to the regulated
entity are $8,570.  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 detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively.

(i)  Respondents Tally

The annual burden for this collection of information is approximately
239 hours per response.  The Total Hour burden is 11,246 and the total
annual labor costs are $1,021,351.

		(ii)  The Agency Tally

	The average annual Agency cost during the three years of the ICR is
estimated to be $9,521.

	6(f)  Reasons for Change in Burden

	There is no change in the total labor hours for the respondents in this
ICR compared to the previous ICR.  This is due to two considerations. 
First, the regulations have not changed over the past three years and
are not anticipated to change over the next three years.  Secondly, the
growth rate for the industry is very low, negative or non-existent. 
Therefore, the burden hour figures in the previous ICR reflect the
current burden to the respondents and are reiterated in this ICR. 
However, there are some minor corrections due to calculation errors. 
There is an increase of one dollar in the total rounded labor cost to
the respondents due to a calculation error in Table 1 of the previous
ICR.  There is an increase in the total number of responses, from 45 to
47, due to a calculation error in “Respondent Universe and Number of
Responses Per Year” in the previous ICR; this results in a decrease in
the per-response hour burden, from 250 to 239 hours per response.

	6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 239 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-2009-0537.  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-2009-0537 and OMB Control Number 2060-0450 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 Industry Burden - NSPS for Commercial and Industrial
Solid Waste Incineration Units (40 CFR part 60, subpart CCCC) (Renewal)

Burden Item	(A)

Respondent Hours per Occurrence (Technical hours)	Emission Testing
Contractor Hours Per Occurrence	Non-Labor Costs Per Occurrence	(B)

Number of Occurrences Per Respondent Per Year	(C)

Hours Per Respondent Per Year

(C=A x B)	(D)

Number of Respondents Per Year a	(E)

Technical Hours Per Year @$87.97 

(CXD) b	(F)

Management Hours Per Year @$100.99

(E x 0.05) b	(G)

Clerical Hours Per Year @$43.81

(E x 0.1) b	(H)

Emission Testing Contractor Hours Per Year @ $100 b	Total Labor Costs

Per Year b

1.	APPLICATIONS	N/A











2.	SURVEY AND STUDIES 	N/A











3.	REPORTING REQUIREMENTS

New Sources













A.	Read Instructions c,d	16 	0 	$0 	1 	16 	1 	16 	0.8 	1.6	0 	$1,558.4

	B.	Required Activities













	1)  Initial requirements c 













	    a)  Initial stack test and report (PM, dioxins/ furans, opacity,
HCI, Pb, Hg, SO2)	24	750	$0	1	24	1	24	1.2	2.4	750	$77,337.6



    b)  Establish and teach operator qualification course c	64	0	$0	1	64
1	64	3.2	6.4	0	$6,233.6



    c)  Obtain  operator qualification 	72	0	$0	1	72	1	72	3.6	7.2	0
$7,012.8



    d)  Establish operating parameters (maximum and minimum)	160
Included in 3B	$0	1	160	1	160	8	16	0	$15,584.1



    e)  Continuous parameter monitoring (including by-pass stack)
initial costs d, e	9	0	$2,240 f	1	9	1	9	0.45	0.9	0	$876.6



    f)  Initial review of site-specific information	Included in 3B













2)  Periodic requirements g













	    a)  Annual stack test and test report (PM, HCl, and Opacity) 	12
125	$0	1	12	30	360	18	36	3,750	$410,064.2



    b)  Annual refresher operator training course	12	0	$0	1	12	30	360	18
36	0	$35,064.2



    c)  Annual review of site-specific information	8	0	$0	1	8	30	240	12
24	0	$23,376.1



    d)  Continuous parameter monitoring (including by-pass stack) annual
costs f	83	0	$211	1	83	30	2,490	124.5	249	0	$242,527.2

	C. 	Create Information	Included in 3B











	D.	Gather Information	Included in 3E











	E.	Report Preparation













	1)  Report prior to construction (includes siting analysis) 	160 	0 	$0
	1 	160 	1 	160 	8 	16 	0 	$15,584.1



2)  Report prior to initial start-up c,i	 	 	 	 	 	 	 	 	 	 	 



    a)  Without site specific parameter petition	6	0	$0	1	6	1	6	0.3	0.6
0	$584.4



    b)  With site specific parameter petition	14	0	$0	1	14	0	0	0	0	0	$0

	   	3)  Report of initial performance test	Included in 3B 	 

 	 	 	 	 	 	 	 

 	   	4)  Siting analysis for new units only (establishes values for
site-specific  operating parameters).c	8	0	$0	1	8	1	8	0.4	0.8	0 	$779.2

	       	5)  Waste management plan c	160	0	$0	1	160	1	160	8	16	0
$15,584.1

	 	6)  Annual Report:













	    a)  Site specific operating parameters	8	0	$0	1	8	30	240	12	24	0
$23,376.1



    b)  Emissions/parameter exceedances and malfunctions k	Included in
3E	0	$0	1	0	3	0	0	0	0	$0



    c)  Results of stack tests conducted during the year	Included in 3B













    d)  Statement of no exceedances k	8	0	$0	1	8	27	216	10.8	21.6	0
$21,038.51



    e)  Documentation of use of by-pass stack	Included in 6B













    f) Documentation for periods when all qualified operators were
unavailable for more than 8 hours	8	0	$0	1	8	30	240	12	24	0	$23,376.1



7)  Status report for operators that are off-site for more than 2 weeks
j	8	0	$0	1	8	3	24	1.2	2.4	0	$2,337.6



8)  Corrective action summary for operators that are off-site for more
than 2 weeks j	8	0	$0	2	16	3	48	2.4	4.8	0	$4,675.2



9)  Semiannual report of emissions/parameter exceedances k	12	0	$0	2	24
3	72	3.6	7.2	0	$7,011.65



 Reporting SUBTOTAL





	10,214	$933,983

4.  Recordkeeping Requirements	 	 	 	 	 	 	 





	A.	Read Instructions	Included in 3A	 	 	 	 	 	 





	B.	Plan Activities	Included in 3B











	C.	Implement Activities	Included in 3B











	D.	Develop Record System	Not applicable











	E.	Record Information













    	1)  Records of operating parameters	Included in 3B 	0	$0	52	0	30	0
0	0	0	$0 

	 	2)  Records of periods for which minimum amount of data on operating
parameters were not obtained	0.5	0	$0	52	26	3	78	3.9	7.8	0	$7,597.24 

	  	3)  Records of malfunction of the unit	1.5	0	$0	1	1.5	3	4.5	0.225
0.45	0	$438.3

	 	4)  Records of exceedances of the operating parameters	1.5	0	$0	1	1.5
3	4.5	0.225	0.45	0	$438.3

	 	5)  Records of stack tests	Included in 3E











	 	6)  Records of siting analysis	Included in 3E











	 	7)  Records of persons who have reviewed operating procedures	1	0	$0
1	1	30	30	1.5	3	0 	$2922

	 	8)  Records of persons who have completed operator training	1	0	$0	1
1	30	30	1.5	3	0 	$2922

	 	9)  Records of persons who meet operator qualification criteria	1	0
$0	1	1	30	30	1.5	3	0 	$2922

	 	10)  Records of monitoring device calibration	Included in 3B	 	 	 	 	
	 	 	 	 



	11) Records of site-specific documentation	24	0	$0	1	24 	30	720	36	72	0
	$70,128.4

	F.	Personnel Training	Included in 3B











	G.	Time for Audits	Not applicable













Recordkeeping SUBTOTAL





	1,032	$87,368

TOTAL:







5,866	293	587	4,500	$1,021,351









	Total Hours	Labor	Non-Labor	Total Labor and No-Labor









Summary of Respondent Burden	11,246	$1,021,351	$8,570	$1,029,921



ASSUMPTIONS:

a.  We assume 700 hours per stack test

b  We assume that all tasks are to be performed by managerial, technical
and clerical personnel.  This ICR uses the following labor rates:
$100.99 for Managerial labor, $87.97 for Technical labor and $43.81 for
Clerical labor.  These rates are from the United States Department of
Labor Bureau of Labor Statistics, “September 2005, Table 2 Civilian
Workers, by Occupational and Industry group.”  The rates have been
increased by 110 percent to account for the benefit packages available
to those employed by private industry.  We also included contractors at
$100/hr.  The labor rate was also taken from the above occupational and
industry group under Blue-Collar occupation that covers Machine
operators, and took the rates from column 1, “Total compensation.”

c.  This activity is based on a one-time cost only.

d  Cost incurred by a facility regardless of the number of affected
units at the plant.

e.  Based on the “Revised Testing and Monitoring Options and Costs for
medical Waste Incinerators (MWIs) - Methodology and Assumptions
(A-91-61,IV-B-66), was assumed that ($300 will be for planning + $500
for selection)/$89.94 per hour = 9 hours.

f   Total capital cost of parameter monitoring for wet scrubbers minus
costs for planning and selecting equipment ($300 + $500) equals: $18,786
- $800 = $17,986.  Based on 0.11746 capital recovery factor, 10 percent
interest rate and 20 year lifetime of the units = $2,113 with a 1.06
cost adjustment = $2,240.

g.  Annual costs are not incurred until the second year that the units
are in operation.

h.  Based on memorandum titled "Revised Testing and Monitoring Options
and Costs for Medical Waste Incinerators (MWI's) - Methodology and
Assumptions [A-91-61, IV-B-66].  83 hours for reporting.  Operation and
maintenance costs - $1,693 * 0.11746 = $199.   $199 * 1.06 cost
adjustment= $211.

i  We assume that one-third of the facilities will petition for
site-specific parameters (6 x 33% = 2).

j  We assume that 10 percent of the facilities would not have a
qualified operator available for more than two weeks at least once a
year.  We assume that this required only two corrective action
summaries.

k  We assume that 10 percent of the facilities would have an exceedance
during the year.

TABLE 2: Annual EPA Burden - NSPS for Commercial and Industrial Solid
Waste Incineration Units (40 CFR part 60, subpart CCCC) (Renewal)

BURDEN ITEMS	(A)

Hours Per Occurrences	(B)

Number of Occurrence Per Year	(C)

Tech Hours Per Year 

@ $42.45

(C=AxB) a	(D)

Management Hours Per Year

@ $57.20

(D=Cx0.05) a	(E)

Clerical Hours Per Year

@ $22.96

(E=Cx0.1)a	(F)

Cost Per 

Year (b)e









































1.	Applications	N/A





	2.	Read and Understand Rule Requirements a&c	16	0	0	0	0	$0 

3.	Required Activities







	A.	Observe initial stack tests b&c









(PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2)	48	0	0
0	0	$0 

	B.	Create Information	N/A







C.	Gather Information	N/A







D.	Report Reviews









1)  Review control plan c	8	0	0	0	0	$0 



2)  Review notification of final compliance c	8	0	0	0	0	$0 



3)  Review waste management plan c	8 	0 	0	0	0	$0 



4)  Review initial stack test report c	40	0	0	0	0	$0 



5)  Review annual compliance report	8	0 	0	0	0	$0 



6)  Review semi-annual excess emission and parameter exceedance report
16	0 	0	0	0	$0 



7)  Review status reports and corrective action summary for operators
off-site	4 	0	0	0	0	$0 

	E.	Prepare annual summary report d	4	50	200	10	20	$9,521

	TOTAL 



200 f	10 f	20 f	$9,521

Assumptions:

a.  Costs are based on the following rates obtained from the Office of
Personnel Management (OPM) “2006 General Schedule” which excludes
locality rates of pay:  1) Managerial at $57.20, 2) Technical at $42.45,
and 3) Clerical at $22.96 per hour.  These rates are increased by 1.6
benefits multiplication factor to account for government overhead
expenses.

b.  Time required to observe initial stack tests (hours per plant):  48 

c.  This is a one-time only cost.

d.  We assume that each state will prepare an annual summary of progress
for implementing the state plan.  One occurrence per year x 50 states =
50 occurrences.

e.  Total costs per year may not correspond with the end total, this is
due to the number being rounded.  Total cost per year:  $8,858.

f.  Total number of EPA hours per year:  230



















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