SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Commercial and Industrial Solid Waste
Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

Emissions Guidelines for Commercial and Industrial Solid Waste
Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal), EPA ICR
1927.05; OMB Control Number 2060-0451

	1(b)  Short Characterization/Abstract

	The Emission Guidelines for Commercial and Industrial Solid Waste
Incineration (CISWI) Units were promulgated on December 1, 2000.  The
guidelines (standards) apply to solid waste incinerators in 40 CFR part
60, subpart DDDD.  These standards fulfill the requirements of sections
111 and 129 of the Clean Air Act (CAA).  This subpart affects the
administrator of an air quality program in a state, or United States
protectorate with one or more existing CISWI units that commenced
construction on or before November 30, 1999.

	The emissions guidelines require: a one-time waste management plan;
initial performance tests for ten pollutants; annual performance testing
for particulate matter (PM), hydrogen chloride (HCl), and opacity;
continuous operating parameter monitoring; annual operator training; and
annual reporting.  A semiannual deviation report is required if any of
the emission limitations or operating limits are exceeded.  The
frequency of these activities was chosen by the United States
Environmental Protection Agency (EPA) as the period that will provide an
adequate margin of assurance that affected facilities will not operate
for extended periods in violation of the standards.

	This supporting statement addresses information collection activities
imposed by the Emission Guidelines for Commercial and Industrial Solid
Waste Incineration (CISWI) Units, subpart DDDD.  The guidelines do not
apply directly to CISWI unit owners and operators.  The guidelines are
implemented through the State Implementation Plans (SIP), written by the
states.  If a state does not develop, adopt, and submit an approved
state plan, and if a state’s plan is not approved, the EPA must
promulgate a Federal Implementation Plan to implement the emission
guidelines in a state without its own SIP.

	The information will be used by enforcement and compliance authorities
to ensure that the requirements of the state, or Federal plans are
implemented and the subject facilities comply with the plans on a
continuous basis.  Specifically, the information will be used by the
authorities to: (1) identify existing sources subject to the standards;
(2) ensure those existing sources have a control plan to achieve
compliance by the final compliance date; (3) ensure that subpart DDDD is
being properly applied; (4) ensure that the emission standards are being
complied with; and     ( 5) ensure, on a continuous basis, that the
operating parameters established during the initial stack test are not
exceeded.

	In addition, records and reports are necessary to enable the
authorities to identify CISWI units that are not in compliance with the
standards.  Based on reported information, the designated administrator
can decide which CISWI units should be inspected and what records or
processes should be inspected at the CISWI unit.  The records that CISWI
units maintain would indicate to the Administrator whether personnel are
operating and maintaining the control equipment properly and whether
they have met the qualification requirements.  In more than 95 percent
of the cases, the enforcement of emission guidelines has been delegated
to the state air pollution control agencies.  In such cases, the reports
required by the standards will be submitted to the appropriate state
agency, and not directly to the EPA.  Thus, there is a minimal
possibility for the duplication of information to state agencies and
EPA.  In those few cases where state agencies have not developed a state
plan or requested delegation of the Federal plan, Federal enforcement
requires information from the CISWI facility.  The plant owner, or
operator may submit a copy of state, or local reports to the EPA
Administrator in lieu of the report required by the standards, as
specified in the General Provisions of 40 CFR part 60.

	This rule requires all records to be maintained at the source for a
period of five years.  These records must be kept on file for use of the
regulating authority to ensure that the plant personnel are operating
and maintaining control equipment properly.

	There are approximately 97 respondents that will be subject to the
standard in the next three years.  The previous Information Collection
Request (ICR) assumed that the facilities regulated under the Emission
Guidelines are owned by “business or other for-profit,” Federal, and
“State, Local; or Tribal Government.”  Recent data indicate that the
ownership is limited to the private industry.  The average annual labor
cost of this ICR is $2,884,100.

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

	The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost - Emission Guidelines for Commercial
and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart
DDDD) (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 - Emission Guidelines for Commercial and Industrial Solid
Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). 

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; . . . .

	Certain reports are necessary to enable the regulatory agencies to
identify existing sources subject to the state plan that implements the
emission guidelines and to determine if the standards are being
achieved.  Therefore, the emission guidelines were promulgated for this
source category at 40 CFR part 60, subpart DDDD.

	2(b)  Practical Utility/Users of the Data

	The information will be used by EPA, state, or local enforcement
personnel to ensure that the requirements of the state or Federal plan
are being implemented and the subject facilities comply with the
requirements of the plans on a continuous basis.  Specifically, the
information will be used to: (1) identify existing sources subject to
the standards; (2) ensure that those existing sources have a control
plan to achieve compliance by the final compliance date;          (3)
ensure that subpart DDDD is being properly applied; (4) ensure that the
emission standards are being complied with; and (5) ensure, on a
continuous basis, that the operating parameters established during the
initial performance test are not exceeded.

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

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

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

	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 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 a local agency can be sent to the Administrator in lieu of the
report requirement 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 97 respondents are
currently subject to the regulation.  The Agency estimates that there
will not be any industry growth in 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.

In addition, it is our policy to review any comments received since the
last ICR renewal including those submitted in response to the First
Federal Register Notice and respond appropriately.  No comments were
received for this ICR.

	

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 on a less frequent basis, 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 violates 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 the reporting, or recordkeeping requirements contains sensitive
questions.

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 could be found in the following table:

Standard	SIC Codes	NAICS Codes

Emission Guidelines for Commercial and Industrial Solid Waste
Incineration Units (40 CFR, part 60, subpart DDDD)



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	321

Manufacturers of wholesale trade, durable goods	25	337

Law enforcement agencies	9229	922

Department of Defense (labs, military bases, munition facilities)	9711
928

Research centers	8221	6113



	4(b)  Information Requested

		(i)  Data Items

	All data in this ICR that are recorded and/or reported are required by
the Emission Guidelines for Commercial and Industrial Solid Waste
Incineration (CISWI) Units (40 CFR part 60, subpart DDDD).

A source must make the following reports:

Notification Reports	Standard Citation by Section

Notification of final control plan	60.2600(a)

Notification of final compliance	60.2605

Submit waste management plan	60.2755 

Notification of initial and subsequent performance tests	60.2760

Notification of closure	60.2615

Annual report	60.2765 and 60.2770

Emission limitation or operating limit deviation report	60.2775, and
60.2780

Qualified operator deviation notification	60.2785(a)(1)

Status Report for operators that are off-site more than two weeks
60.2785(a)(2)

Notification of resumed operation	60.2785(b)

Notification until increment is met	60.2595



A source must keep the following records:

Recordkeeping

Records of initial performance tests, annual performance tests, and any
subsequent performance tests.	60.2740(f)

Maintain records of days for which data on operating parameters have
been obtained.  Includes a list of operating parameters not measured,
reason for not measuring, and a description of corrective actions taken.
60.2740(c)

Maintain records of occurrence and duration of any malfunction and the
corrective action taken.	60.2740(d)

Maintain records of days when deviation from operating limits has
occurred, and description of corrective actions taken.	60.2740(e)

Maintain records of names of persons who have completed review of
site-specific information and incinerator operating procedures.
60.2740(g) and 60.2660(c)

Maintain records of names of persons who have completed the operator
training requirements.	60.2740(h)

Maintain records of phone and/or pager numbers of persons who have met
the operator qualification criteria.	60.2740(i)

Maintain records of calibration of monitoring devices.	60.2740(j)

Maintain records of equipment vendor specifications for the incinerator,
emission controls, and monitoring equipment.	60.2740(k)

Maintain records of daily log of quantity and types of waste burned.
60.2740(m)

Maintain records of site-specific information and incinerator operation
procedures.	60.2660(c)

Maintain records of operating parameters.	60.2740(b)

Maintain calendar date of each record.	60.2740(a)

Retain records for five years.	60.2740

Electronic Reporting

	Currently, sources are using monitoring equipment that provides
parameter data in an automated way (e.g., leaks and spills of mercury). 
Personnel at the source will 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 reduces 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 and annual performance tests.

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.

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 Air Facility System.

Observe compliance tests (optional)



	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 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.

	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

	An exact number of small entities affected by this rule could not be
determined based on review of available documentation.  According to the
Final Rule (68 FR 57517): 

During the 2000 CISWI emission guidelines rulemaking, the EPA determined
that based on the low number of affected small entities in each
individual market, the alternative method of waste disposal available,
and the relatively low control cost, the CISWI emission guidelines
should not generate a significant small business impact on a substantial
number of small entities in the commercial and industrial sectors.

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.

The rules contain several provisions that reduce the impact of the rule
on all regulated entities which includes small entities.  These are: 

1..Annual performance testing is only required for three pollutants
rather than the full ten pollutants included in the initial performance
tests.

2..Operating parameter monitoring is required instead of continuous
emissions monitoring systems (CEMS).

3..The owner or operator is allowed to skip two annual performance tests
for a pollutant if all performance tests over the previous three years
show compliance.

4,  Deviation reports are only required if there is a deviation,
otherwise reporting is annual.

	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 - Emissions Guidelines for Commercial and Industrial Solid Waste
Incineration Units (40 CFR part 60, subpart DDDD) (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 a 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 31,619
hours (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 Emissions Guidelines 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:  $100.99 per hour for
Executive, Administrative, and Managerial labor, $87.97 per hour for
Technical labor, and $43.81 per hour for Clerical labor.  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 have been increased by 110 percent to
account for the benefit packages available to those employed by private
industry.

	Managerial	$100.99   ($48.09 + 110%)

Technical	$87.97     ($41.89 + 110%)

	Clerical	$43.81     ($20.86 + 110%)

		(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 cost 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

(A)

Capital/Startup Cost for One Respondent1	(B)

Number of Initial Respondents2	(C)

Total Capital/Startup Cost

(A x B)	(D) 

Annual O&M Costs for One Respondent3	(E)

Number of Respondents with O&M 2	(F) Total O&M, (E x F)	(G)

Total 

(C + F)

$2,240	0	$0	$211	97 	$20,467	$20,467

		1  The capital/startup costs and O&M could be found in Table 1 under
column “Non-labor costs per occurrence per respondent” and “Total
non-labor costs per year”.  Section 3B(1e) and (2d).

		2  See Section 6(d) for calculation.

		3  We assume that the annual O&M cost are $211 per year.

	The total capital/startup costs for this ICR are zero.  This is the
total of column C in the above table.  The total operation and
maintenance (O&M) costs for this ICR are $20,467.  This is the total of
column F.  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
this ICR is estimated to be $20,467.

	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 $46,463 (rounded).  This cost is based on the average
hourly labor rate at a GS-12, Step 1, times 1.6 benefits multiplication
factor to account for government overhead expenses.  The rates are 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, $114.35 x 1.6)

 

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear below in Table 2: Average Annual EPA
Burden - Emissions Guidelines for Commercial and Industrial Solid Waste
Incineration Units (40 CFR part 60, subpart DDDD) (Renewal).

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

	As shown above, the average Number of Respondents over the three-year
period of this ICR is 97.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of Initial Respondents 	(B)

Number of Existing Respondents 	(C) 

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

Number of Existing Respondents with Initial Requirements	(E)

Number of Respondents (E=A+B+C-D)

Average	0	97	0	0	97



The total number of annual responses per year is calculated using the
following table:

Total Annual Responses

(A)

Number of Initial Respondents	(B)

Number of Reports for Initial Respondents	(C) 

Number of Existing Respondents	(D) 

Number of Reports for Existing Respondents	(F)

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

Total Annual Responses E=(AxB)+(CxD)

0	0	97	1.41	0	136 (Rounded)

1 Each existing respondent submits an annual report.  10 percent submit
an operator status notification of resumed operation.  10 percent submit
status report for operators that are off-site for more than two weeks. 
10 percent submit a corrective action summary report.  10 percent submit
a semiannual exceedance report.  Total number of reports per respondent
is 1.4 per year.

	The number of Total Annual Responses from the 97 respondents is 136. 
The Total Hours Requested is 31,619.  The total annual labor costs are
$2,884,100.  Details of the labor cost estimates may be found below in
Table 1: Annual Respondent Burden and Cost - Emission Guidelines for
Commercial and Industrial Solid Waste Incineration Units (40 CFR part
60, subpart DDDD) (Renewal).

 

	Note that the total annual capital and O&M costs to the regulated
entity are $20,467.  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 is estimated to
average 232 hours per response.

	6(f)  Reasons for Change in Burden

There is no change in the cost to the respondents in this ICR 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.  Therefore,
the cost figures in the previous ICR reflect the current burden to the
respondents and are reiterated in this ICR.  There is, however, a
decrease of one hour in the total labor hours to the respondent in this
ICR due to rounding.  

In accordance with the Paperwork Reduction Act, actions related to case
development activities have been removed from the Agency cost figures. 
Therefore, the cost to the Agency as reported in this ICR has been
reduced.

	

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 232 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-2009-0542.  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-2009-0542 and OMB Control Number 2060-0451 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 - Emission Guidelines for
Commercial and Industrial Solid Waste Incineration Units (40 CFR Part
60, Subpart DDDD) (Renewal)

Burden Items	(A)

Respondent Hours per Occurrence (Technical hours)	(B)

Number of Occurrences Per Respondent Per Year	(C)

Hours Per Respondent Per Year

(C = A x B)	(D)

Number of Respondents Per Year	(E)

Technical Hours Per Year @$87.97

(C x D) 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)

Total Labor Costs 

Per Year b	(I)

Emission Testing Contractor Hours Per Occurrence per Respondent	(J)

Emission Testing Contractor Hours Per Year 

(D x I)	(K)

Non-Labor Costs Per Occurrence per Respondent	Total Contractor/
Non-Labor Costs Per Year

(D x K) +

(J x $100) k

1.	APPLICATIONS	N/A











	2.	SURVEY AND STUDIES	N/A











	3.	REPORTING REQUIREMENTS

New Sources













	A.  Read Instructions c&d	16	1 	16 	0 	0 	0	0 	$0	0 	0 	$0 	$0 

	B.  Required Activities















1)  Initial requirements a, c















    a)  Initial stack test (PM, dioxins/furans, opacity, HCl, Pb, Hg,
SO2)

    b)  Establish and teach operator qualification course 

    c)  Obtain operator qualification

    d)  Establish operating parameters (maximum and minimum) 

    e)  Continuous parameter monitoring (including by-pass stack)
initial costs	16

64

72

160

9 e

	1

1

1

1

1	16

64

72

160

9 	0a

0a

0a

0a

0a	0

0

0

0

0	0

0

0

0

0	0

0

0

0

0	$0

$0

$0

$0

$0	0

0

0

Included in 3B(a)

0

	0

0

0

0

0	$0 

$0

$0

$0

$0	$0

$0

$0

$0

$0



2)  Periodic requirements 

    a)  Annual stack test and test report (PM, HCl, and Opacity) 

    b)  Annual refresher operator training course

    c)  Annual review of site-specific information 

    d)  Continuous parameter monitoring (including by-pass stack) annual
costs 	

12

12

8

83

 	

1

1

1

 1 	

12

12

8

 83 	

97g

97g

97g

97g	

1,164

1,164

776

8,051	 

58.2

58.2

38.8

402.55	 

116.4

116.4

77.6

805.1	

$113,374.18

$113,374.18

$75,582.79

 $784,171.42	

125

0

0 

0	

12,125

0

0

0 	

$0

$0

$0 

$211h 	

$1,212,500

$0

$0

$20,467 

	C.  Create Information	Included in 3B













D.  Gather Information	Included in 3E













E.  Report Preparation















1)  Control plan

2)  Notification of final compliance 

3)  Report of initial performance test

4)  Siting analysis for new units only (established values for
site-specific operating parameters

5)  Waste management plan	40

4

8 

8

160	 1 

1

1

1

1	40

4

8

8

160	0

0

0

0

0	 0

 0

0

0

0	0

0

0

0

0	0

0

0

0

0	$0

$0

$0

$0

$0	0

0

50

0

0	0

 0

0 

0

0	 $0 

$0

$0

$0

$0	$0

$0

$0

$0

$0



6)  Annual Report: g















	a)  Site specific operating parameters	8 	1 	8 	97	776	38.8	77.6
$75,582.79	0 	0	$0 	$0



	b)  Emissions/parameter exceedances and malfunctions 	Included in 3E 10





 









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















d)  Statement of no exceedances 	8 	1 	8	97	776	38.8	77.6	$75,582.79	0 
0 	$0 	$0



	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 	1 	8 	97	776	38.8	77.6	$75,582.79	0
	0 	$0 	$0



7)  Status report for operators that are off-site for more than 2 weeks
i	8 	1 	8 	10	80	4	8	$7,792.04	0 	0	$0 	$0



8)  Corrective action summary for operator that are off-site for more
than 2 weeks i	8	2	16	10	160	8	16	$15,584.08	0	0	$0	$0



9)  Qualified operator deviation notification of resumed operation	8 	1 
8	10	80 	4	8	$7,792.04	0 	0 	$0 	$0 



10)  Semiannual report of emissions/parameter exceedances j	24 	1 	 24 
10	240	12	24	$23,376.12	0 	0 	$0 	$0 

Subtotal Reporting



	16,149	$1,367,795

12,125

$1,232,967

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	N/A













E.  Record Information 















1)  Records of operating parameters	Included in 3B 













	2)  Records of periods for which minimum amount of data on operating
parameters were not obtained	0.5	52	26	10	260	13	26	$25,324.13	0	0	$0	$0



3)  Records of malfunction of the unit	1.5 	1 	1.5 	10	15	0.75	1.5
$1,461	0 	0 	$0 	$0 



4)  Records of exceedances of the operating parameters	1.5 	1 	1.5 	10
15	0.75	1.5	$1,461	0 	0 	$0 	$0 



5)  Records of stack tests	Included in 3E













	6)  Records of persons who have reviewed operating procedures	1	1	1	97
97	4.85	9.7	$9,447.85	0	0	$0	$0



7)  Records of persons who have completed operator training	1 	1 	1 	97
97 	4.85	9.7	$9,447.85	0 	0 	$0 	$0 



8)  Records of persons who meet operator qualification criteria	1	1	1	97
97	4.85	9.7	$9,447.85	0	0	$0



	9)  Records of monitoring device calibration	Included in 3B 	 	 	 	 	 	
	 	 	 	 	 



10) Records of site-specific documentation	24 	1 	24 	97	2,.328	116.4
232.8	$226,748.36	0 	0 	$0 	$0 

	F.  Personnel Training	Included in 3B





 

 

 



G.  Time for Audits	N/A











	Subtotal Recordkeeping



	3,345	$283,338

0

$0

TOTAL



	19,494	$1,651,133

12,125

$1,232,967







	Labor Hours	 Contractor Labor Hours	Total Hours	Labor Cost
Contractor/Non-Labor Cost	Total Cost

	e





Summary of Respondent Burden

Annual Capital/Startup Costs

O & M Summary	19,494	12,125	31,619	$1,651,133.28	$1,232,967

$0

$20,467	$2,884,100

$20,467

	

Assunptions:

a.  The average number of respondents per year over the three-year
period of the renewal is 97.

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, December 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.  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), the assumption is 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 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.  Respondents make one combined annual report per year.

h.  Based on memorandum titled "Revised Testing and Monitoring Options
and Costs for Medical Waste Incinerators (MWIs) - Methodology and
Assumptions [A-91-61, IV-B-66], the respondents spend 83 hours for
reporting; operation and maintenance costs - $1,693 x 0.11746 = $199;
$199 x 1.06 cost adjustment = $211.

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

j.  Assume that 10 percent of the facilities would have an exceedance
during the year.

k.  Assume that the average cost for contractor is $100.00 per hour.

TABLE 2:  Average Annual EPA Burden - Emission Guidelines for
Commercial and Industrial Solid Waste Incineration Units (40 CFR Part
60, Subpart DDDD)

BURDEN ITEMS	(A)

Hours Per Occurrences	(B)

 Number of Occurrence Per Year a	(C)

Tech Hours Per Year @ $42.45

(C = A x B) b	(D)

Management Hours Per Year @ $57..20

(D = C x 0.05) b	(E)

Clerical Hours Per Year @ $22.96

(E = C x 0.1) b	(F)

Cost Per Year 

1.	Applications	N/A





	2.	Read and Understand Rule Requirements 	16	0	0	0	0	$0

3.	Required Activities









Report Reviews









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



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



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



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



5)  Review annual compliance report	8	97	776	38.8	77.6	$36,942.22



6)  Review semi-annual excess emission and parameter exceedance report
16	10	160	8	16	$7,616.96



7)  Review status reports and corrective action summary for operators
off-site	4 	10	40	2	4	$1,904.24

	TOTAL 



1,122  (rounded)	$46,463  (rounded)



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 and multiplied by 1.6 to account for government
overhead expenses: 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.  We assume that 10 percent of the facilities will have exceedance
reports and operator off-site reports.

c.  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.

d.  We assume that 10 percent of the compliance tests (annual or
initial) are observed, and that it takes
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