SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and Eb)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and Eb)
(Renewal), EPA ICR Number 1506.12, OMB Control Number 2060-0210

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for subpart Ea and subpart
Eb were proposed on December 20, 1980 and September 20, 1994
(respectively), and promulgated on February 11, 1991 and December 19,
1995 (respectively).  Municipal waste combustor (MWC) facilities that
commenced construction after December 20, 1989 and on or before
September 20, 1994, or commenced modification or reconstruction after
December 20, 1989 and on or before June 19, 1996, are subject to the
regulations in 40 CFR part 60, subpart Ea.  MWC facilities which
commenced construction after September 20, 1994, or commenced
modification or reconstruction after June 19, 1996, are subject to the
regulations in 40 CFR part 60, subpart Eb.  This information is being
collected to assure compliance with 40 CFR part 60, subparts Ea and Eb.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports by the owners or operators of
the affected facilities.  They are also required to maintain records of
the occurrence and duration of any start-up, shutdown, or malfunction in
the operation of an affected facility, or any period during which the
monitoring system is inoperative.  These notifications and records are
essential in determining compliance, and are required of all sources
subject to the NSPS.

Owners or operators subject to the provisions of subpart Ea 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.  Any owner or operator subject to the provisions of subpart
Eb will maintain a file of these measurements, and retain the file for
at least five years following the date of such measurements, maintenance
reports, and records.  In addition, annual compliance reports are
required for respondents (i.e., sources), along with semiannual reports
of excess emissions, and quarterly reports for both subparts Ea and Eb.

Based on our consultations with industry representatives, there is an
average of twelve sources that are subject to subparts Ea and Eb.  There
are seven sources that are subject to Ea, and it is estimated that no
additional sources will become subject to the regulation in the next
three years, since the latest applicability date was June 19, 1996.  It
is further assumed that there are two affected facilities per plant per
respondent (i.e., the owner or operator of the plant site).  The
remaining five sources are subject to subpart Eb, and it is estimated
that one additional source per year will become subject to the standard
over the next three years.  It is further assumed that there is an
average of two affected facilities per plant.

In the United States, there are approximately 12 municipal waste
combustor plants that are all publicly owned and operated by the
municipal waste combustor industry.  None of these facilities are owned
by either state, local, tribal, or the Federal governments.  They are
all owned and operated solely by privately owned for-profit businesses. 
You can find the burden to the “Affected Public” listed below in
Table 1: Annual Industry Burden and Cost - NSPS for Municipal Waste
Combustors (40 CFR Part 60, Subparts Ea and Eb).  The Federal government
burden does not include work performed by Federal employees only work
performed by contractors, which could be found listed below in Table 2:
Average Annual EPA Burden - NSPS for Municipal Waste Combustors (40 CFR
Part 60, Subparts Ea and Eb).

In the development of the Information Collection Request (ICR), we
addressed the Office of Management and Budget (OMB) “Terms of
Clearance (TOC)” on the active ICR.  The TOC are as follows:

When this ICR is renewed, EPA should review the respondent burden,
universe, labor rates, and capital costs and ensure these estimates have
been updated.

EPA has addressed each item of concern in the TOC.  The respondent
burden, universe, labor rates, and capital cost, have been thoroughly
checked and all estimates updated.

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 addition, section 114(a) states that the Administrator may require
any owner or operator subject to any requirement of this Act 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 Administrator 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.

In the Administrator's judgment, organic, acid gas, and nitrogen oxide
emissions from MWCs 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, subparts Ea and Eb.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations.  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 standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance tests, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standard 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standard is being met.  The performance test may also be observed.

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

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, subparts Ea and Eb.

3(a)  Nonduplication

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 (76 FR 26900) on May 9, 2011.  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.  The primary source of information as
reported by industry is the Online Tracking Information System (OTIS)
which is operated and maintained by the EPA Office of Compliance.  OTIS
is the EPA database for the collection, maintenance, and retrieval of
all compliance data.  The growth rate for the industry is based, in
part, with our consultations with the Office of Air Quality Planning and
Standards (OAQPS).

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.  In developing the ICR, we contacted the
Integrated Waste Service Association at (202) 467-6240. 

It is our policy to respond after a thorough review of comments received
since the last ICR renewal, as well as to those submitted in response to
the First Federal Register Notice.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

 	

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 (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
municipal waste combustors.  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 (40 CFR Part 60, Subparts Ea and Eb)	

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 hazardous waste treatment and disposal)	

4953	

562219



Refuse Systems (solid waste combustors and incinerators)	

4953	

562213



Refuse Systems (solid waste landfills)	

4953	

562212



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

In this ICR, all the data recorded or reported is required by the New
Source Performance Standards for Municipal Waste Combustors (40 CFR Part
60, Subparts Ea and Eb).

A source must make the following reports:

Notification

Notification of construction/reconstruction or modification	60.7(a)(1),
60.59a(a), 60.59b(a-c)

Notification of preconstruction plans and public meeting material
60.59b(a)

Notification of actual startup	60.7(a)(3), 60.59a(a), 60.9b(c)

Notification related to siting analysis	60.59b(a)

Notification of initial performance tests	60.8(d)

Notification of initial performance tests results	60.8(a)

Notification of demonstration of continuous monitoring system	60.7(a)(5)

Notification of physical or operational change	60.7(a)(4)

Notification related to opacity	60.7(a)(6), 60.59b(c)



Reports

Report on initial performance test results	60.8(a), 60.59a(c), 60.59b(f)

Report on public meeting (notification and transcript)	60.59b(a)(2-3), 

Report on responses to public comment	60.59b(a)(4)

Report on preliminary and final draft materials separation plans
60.59b(a)(1)

Report on weights of municipal solid waste and other fuels fired
60.59a(b)(3)

Report on performance tests/compliance report	60.8(a), 60.59a(e),
60.59a(g), 60.59b(g)

Report excess emissions	60.59a(f), 60.59b(h)

Report on continuous emission monitoring system (CEMS) demonstration and
test data	60.8(a), 60.59b(f)

Report of emission levels during annual test (if necessary)	60.59b(d)

Semiannual report and explanation for excess emissions (if necessary)
60.59b(d)

Semiannual carbon report for mercury control (if necessary)	60.59b(d)



A source must keep the following records:

Recordkeeping 

Initial performance tests and annual performance tests	

60.59b(d)

Records of periodic testing for fugitive ash emissions	60.59b(d)

Startup, shutdown, malfunction periods where the continuous monitoring
system is inoperative	60.7(b)

Occurrence, duration of interruption in operation	60.7(b)

Records of sources with continuous monitoring systems	60.59a(i)

Results of daily CEMs drift tests and Appendix F accuracy assessment
60.59b(d)

Amounts of sorbent used for mercury (Hg) control	60.59b(d)

Persons reviewing operating material	60.59a(j), 60.59b(d)

Records are required to be retained for two years (subpart Ea)	60.59a(b)

Records are required to be retained for five years (subpart Eb)
60.59b(d-e)



Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity.

Perform initial performance test, Reference Methods 19 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 processing and maintaining 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.

Perform site selection analysis.

Hold public meeting on site analysis and material separation plan.



	Electronic Reporting

Some of the respondents use monitoring equipment that automatically
records parameter data.  Although personnel at the affected facility
must still evaluate the data, internal automation has significantly
reduced the burden associated with monitoring and recordkeeping at a
plant site.

Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

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,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



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

The majority of the respondents are large entities (i.e., 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 to be the minimum
requirements 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 for NSPS
for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and Eb)
(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.  Wherever 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 20,421
(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	$118.92   ($56.63 + 110%)   

Technical	$97.78   ($46.56 + 110%)

Clerical	$48.76   ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2010, “Table 10. Private industry, 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 only costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
The type of industry costs 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 costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor 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)

CEMs for subpart Ea	$60,000	0	$0	$8,972	7	$62,804

CEMs for subpart Eb	$60,000	1	$60,000	$8.972	4	$35,888

Total

	$60,000

	$98,692



The total capital/startup costs for this ICR are $60,000.  This is the
total of column D in the above table. 

The total operation and maintenance (O&M) costs which consist of
photocopying and postage are $98,692.  This is the total of column G. 

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $158,692.

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 $36,556.

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) “2011
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 in Table 2: Average Annual EPA Burden, NSPS for Municipal
Waste Combustors (40 CFR Part 60, Subparts Ea and Eb) (Renewal). 

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

	

Based on our research for this ICR, approximately 198 respondents are
currently subject to the standard.  It is estimated that an additional
one source per year under subpart Eb will become subject to the standard
in the next three years.  The average number of respondents per year is,
therefore: 1) subpart Ea - 7 existing, and zero new; and 2) subpart Eb -
4 existing, and one new.  The average number of existing respondents per
year is 11, with one new for a total of 12 sources.  This is illustrated
below.

The number of respondents is calculated using the following table that
addresses the three years covered by this ICR.  

Number of Respondents

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-Ea	0	7	0	0	7

2-Ea	0	7	0	0	7

3-Ea	0	7	0	0	7

1-Eb 2	1	4	0	1	4

2-Eb	1	5	0	1	5

3-Eb	1	6	0	1	6

Average	1	12	0	1	12

1 The new respondent includes sources with constructed, reconstructed,
and modified affected facilities.

2 The average number of existing respondents for subpart Eb is four.  

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 12.

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 of construction/reconstruction for Ea	0	0	N/A	0

Notification of actual startup for Ea	0	0	N/A	0

Notification of initial performance test for Ea	0	0	N/A	0

Notification of CMS demonstration for Ea	0	0	N/A	0

Notification of construction/reconstruction for Eb	1	1	N/A	1

Notification of initial performance test for Eb	1	1	N/A	1

Compliance reports for Ea	7	1	N/A	7

Opacity reports for Ea (no excess emission)	5.6	1	N/A	5.6

Opacity reports for Ea (excess emission)	1.4	1	N/A	1.4

Report of daily weight of municipal solid waste (MSW) and fuel for Ea	7
4	N/A	28

Appendix F reports for Ea	7	4	N/A	28

Initial compliance reports for Eb	1	1	N/A	1

Annual compliance reports for Eb	4	1	N/A	4

Semiannual excess emission reports Eb	4	2	N/A	8

Appendix F quarterly reports for Eb	4	4	N/A	16

Initial report on site selection analysis for Eb	1	1	N/A	1

Public meetings and comment responses for Eb	1	1	N/A	1



	Total	103



The number of Total Annual Responses is 103.

The total annual labor costs are $1,757,811.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NSPS for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and Eb)
(Renewal).

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

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

(i)  Respondent Tally

The total annual labor costs are $1,757,811.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NSPS for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and Eb)
(Renewal).  

Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 198 hours per
response.

The total annual capital/startup and operation and maintenance (O&M)
costs to the regulated entity are $159,000 (rounded).

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 785 labor hours at a cost of $36,556.  See Table 2.
Annual Agency Burden and Cost: NSPS for Municipal Waste Combustors (40
CFR Part 60, Subparts Ea and Eb) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost 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
industry is very low, negative, or non-existent, so there is no
significant change in the overall burden.  There is, however, an
increase in the estimated burden cost as currently identified in the OMB
Inventory of approved Burdens.  The increase is not due to any program
changes.  The change in burden cost is due to the use of the most
updated labor rates.  

Since there are no changes in the regulatory requirements and there is
no significant industry growth, the labor hours and cost figures in the
previous ICR are used in this ICR, and there is no change in burden to
industry.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 198 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-2011-0210.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
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 content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than 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 Enforcement and
Compliance Docket and Information Center Docket is (202) 566-1927. 
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-2011-0210 and OMB Control
Number 2060-0210 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 Municipal
Waste Combustors (40 CFR part 60, subparts Ea and Eb)

 

Burden item	(A)

Technical Person- Hour Per Occurrence

	(B)

Number of

Occurrences

Per

Respondent

Per Year

	(C)

Technical

Person-

Hour Per

Respondent

Per Year

(C=AxB)	(D)

Number of

Respondents

Per Year a

	(E)

Technical

Person-

Hour

Per Year

(E=CxD)b

	(F)

Management

Person-

Hour

Per Year

(E x 0.05)b

	(G)

Clerical

Person-

Hour

Per Year

(E x 0.1)b

	(H)

Total

Labor Costs

Per Year b

	(I)

Emission

Testing

Contractor

Hours Per

Occurrence

	(J)

Emission

Testing

Contractor

Hour Per

Respondent

Per Year

(J= IxB)	(K)

Contractor

Person-

Hour

Per Year

(K= JxD)

	(L)

Total

Contractor

Cost

Per Year

(L=Kx$80) c

1. Applications	N/A	 

 	 

 



	  

2. Survey and Studies	N/A	 

 	 

 



	  

3. Reporting requirements	 	 

 	 

 



	  

  A.  Read instructions	1	1	1	2	2	0.1	0.2	$217.20	1	1	2	$160.00

  B.  Required activities













      Initial performance test   

      for Eb d, e	24	1	24	1	24	1.2	2.4	$2,576.44	1,053	1,053	1,053
$84,240.00

      Repeat performance

      test for Eb f, e                                                  
                   	24	1	24	0.2	4.8	0.24	0.48	$521.76	1,053	1,053	210.6
$16,848.00

      Demonstration/CEMS for Eb	24	1	24	1	24	1.2	2.4	$2,606.44	470	470
470	$37,600.00

      Repeat CEM

      demonstration Eb g	24	1	24	0.2	4.8	0.24	0.48	$521.76	470	470	94
$7,520.00

      Annual compliance test 

      for Ea h, i	24	1	24	7	168	8.4	16.8	$18,245.14	826	826	5,782
$462,560.00

      Annual compliance test

      for Eb j, e	24	1	24	4	96	4.8	9.6	$10,425.80	1,053	1,053	4,212
$336,960.00

      Appendix F audit for Ea

      (in-situ)	125	8	1,000	0	0	0	0	$0	0	0	0	$0

      Appendix F audit for Ea

      (extractive)	36	8	288	0	0	0	0	$0	0	0	0	$0

  C.  Create Information	See 3B











	  D.  Gather information 	See 3B











	  E.  Write report  













      Notification of  construction/

      reconstruction for Ea       	2	1	2	0	0	0	0	$0	0	0	0	$0

      Notification of actual 

      startup – Ea	2	1	2	0	0	0	0	$0	0	0	0	$0

      Notification of initial

      performance test - Ea 	2	1	2	0	0	0	0	$0	0	0	0	$0

      Notification of CMS

      demonstration for Ea                                              
2	1	2	0	0	0	0	$0	0	0	0	$0

      Notification of construction/

      reconstruction for Eb	2	1	2	1	2	0.1	0.2	$217.20	0	0	0	$0

      Notification of initial

      performance test – Eb	2	1	2	1	2	0.1	0.2	$217.20	0	0	0	$0

     Annual compliance

     reports for Ea	16	1	16	7	112	5.6	11.2	$12,163.42	0	0	0	$0

     Annual opacity report of 

     no excess emission for Ea k	8	1	8	5.6	44.8	2.24	4.48	$4,865.36	0	0
0	$0

     Annual opacity report for

     excess emission for Ea l	16	1	16	1.4	22.4	1.12	2.24	$2,432.68	0	0	0
$0

     Report of daily weight of

     MSW and fuel for Ea	34	4	136	7	952	47.6	95.2	$103,389.10	0	0	0	$0

     Appendix F reports for Ea	11	4	44	7	308	15.4	30.8	$33,449.42	0	0	0
$0

     Initial compliance report

     for Eb	40	1	40	4	160	8	16	$17,376.32	0	0	0	$0

     Annual compliance report

     for Eb	40	1	40	4	160	8	16	$17,376.32	0	0	0	$0

     Semiannual excess 

     emission report Eb m	17	2	34	4	136	6.8	13.6	$ 14,769.88	0	0	0	$0

     Appendix F reports for Eb n	11	4	44	4	176	8.8	17.6	$19,113.96	0	0	0
$0

     Initial site selection

     analysis/report for Eb	270	1	270	4	1,080	54	108	$117,290.16	0	0	0
$0

     Public meeting and

     comment response for Eb	140	1	140	4	560	28	56	$60,817.12	0	0	0	$0

Subtotal for reporting 





4,644.62



	11,823.6

	4.  Recordkeeping  requirements













A.  Read instructions	See 3A











	    B.  Plan activities	See 4E









	  

    C.  Implement activities	See 4E









	  

D.  Develop record system 	See 4E









	  

E.  Time to enter information













 Records of SSM for Ea o	1.5	104	156	7	1,092	54.6	109.2	$118,593.38	0	0
0	$0

 Record emission 

 measurements Ea o	1.5	104	156	7	1,092	54.6	109.2	$118,593.38	0	0	0	$0

 Record of employee 

 review of operation for Ea p	4	2	8	7	56	2.8	5.6	$6,081.72	0	0	0	$0

 Record of emission rates,

 and computation tests for Eb q 	1.5	94	141	4	564	28.2	56.4	$61,251.52	0
0	0	$0

 Record of SSM for Eb q	1.5	94	141	4	564	28.2	56.4	$61,251.52	0	0	0	$0

 Record of employee

 review of operation for Eb r	4	2	8	4	32	1.6	3.2	$3,475.26	0	0	0	$0

 Record amount of  sorbent

 for Hg control for Eb 	0.1	94	9.4	4	37.6	1.88	3.76	$4,083.44	0	0	0	$0

    F.  Train personnel	See 4E











	    G.  Audits	See 4E











	Subtotal for recordkeeping





3,953.24







Subtotal



	7,476.4	373.82	747.64	$811,922.90

	11,823.6	$945,888.00

TOTAL LABOR BURDEN AND COST	Labor Hours (E+F+G)                        
8,597.86	                    Labor Cost                                 
                    $811,922.90



Contractor Labor Hours                    11,823.6	                   
Contractor Labor Cost                                $945,888.00



Total Hours                                       20,421.46	            
       Total Cost                                               
$1,757,810.90



Total Hours (rounded)                      20,421	                   
Labor Cost                                                  $811,922.90

	

Assumptions:

a  We have estimated that an average of 12 sources are subject to
subparts Ea and Eb.  Seven of these sources are currently subject to
subpart Ea, with no additional sources

becoming subject to the regulation in the next three years.  The
remaining five sources are subject to subpart Eb (4 existing and 1 new).
 We have assumed that one additional

source per year will become subject to the standard over the next three
years.  It is further assumed that there is an average of two affected
facilities per plant per respondent.

b       b  This ICR uses the following labor rates:  $118.92 per hour
for Executive, Administrative, and Managerial labor; $97.78 per hour for
Technical labor, and $48.76 per hour

      for Clerical labor.  These rates are from the United States
Department of Labor, Bureau of Labor Statistics, December, 2010, Table
2. Civilian Workers, by Occupational

      and Industry groups.  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.

c  We have estimated that the contractors’ rate would be $80.00 per
hour.

d  We have assumed that one respondent will take 24 hours to perform
initial performance test.

e  We have assume that it will take an emission testing contractor 1,053
hours to perform both initial performance test and repeat performance
test for subpart Eb.

f  We have assumed that 20 percent of the respondents will repeat
performance test for Eb.

g  We have assumed that 20 percent of respondents will repeat CEM
demonstration activity for Eb.

h  We have assumed that all of the seven respondents for subpart Ea will
have to complete an annual compliance test.

i  We have assumed that it will take an emission testing contractor 826
hours to complete an annual compliance test for Eb.

j  We have assume that four respondents for subpart Eb will have to
complete an annual compliance test.

k  We have assumed that 80 percent of respondents will file an opacity
report of no excess emission for Ea.

l  We have assumed that 20 percent of respondents will file an opacity
report of excess emission for Ea.

m  We have assumed that four of the respondents will be required to
write semiannual excess emission report for Eb two times per year.

n  We have assumed that four of the respondents will write the appendix
F reports four times per year.

o  We have assumed that all seven respondents for subpart Ea will each
take 104 hours to complete task.

p  We have assumed that all respondents for subpart Ea will each take 4
hours two times per year to record employee review of operations.

q  We have assumed that each of the four respondents will take 1.5 hours
94 times per year to enter information.

r  We have assumed that each of the four respondents for subpart Eb will
take four hours two times per year to enter employee review of operation
information.



Table 2:  Average Annual EPA Burden – NSPS for Municipal Waste
Combustors (40 CFR part 60, subparts Ea and Eb)

Activity	(A)

EPA person- hours per occurrence	(B)

No. of occurrences per plant 

per year	(C)

EPA person- hours per plant per year (C=AxB)	(D)

Plants per year (a)	(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)

Cost ($) b

Initial performance tests for Ea	180	1	180	0	0	0	0	$0

Review report of initial performance test for Ea	24	1	24	0	0	0	0	$0

Repeat performance test for Ea	12	1	12	0	0	0	0	$0

Repeat performance test for Eb c	12	1	12	0.2	2.4	0.12	0.24	$124.37

Report review for Ea









    Notification of construction	2	1	2	0	0	0	0	$0

    Notification of actual startup	2	1	2	0	0	0	0	$0

    Notification of initial test                      	2	1	2	0	0	0	0	$0

    Notification of CMS demonstration	12	1	12	0	0	0	0	$0

Review of CEMS demonstration for Ea	96	1	96	0	0	0	0	$0

Report review for Eb d









    Notification of construction	2	1	2	1	2	0.1	0.2	$103.65

    Notification of actual startup	2	1	2	1	2	0.1	0.2	$103.65

    Notification of initial performance test	8	1	8	1	8	0.4	0.8	$414.60

    Notification of CEMS demonstration	5	1	5	1	5	0.25	0.5	$256.62

Review CEMS demonstration for Eb	40	1	40	1	40	2	4	$2,072.98

Review excess emission reports for Ea









    No excess emission report e	8	1	8	5.6	44.8	2.24	4.48	$2,321.73

    Excess emission report f	2	1	2	1.4	2.8	0.14	0.28	$1,309.60

Review semiannual excess emission reports for Eb g	12	2	24	4	96	4.8	9.6
$4,973.16

Review quarterly appendix F reports for Ea h	0.5	4	2	7	14	0.7	1.4
$725.54

Review quarterly compliance report for Ea h	8	4	32	7	224	11.2	22.4
$11,608.68

Review annual compliance reports for Eb i	5	1	5	4	20	1	2	$1,036.49

Review annual compliance tests for Ea j	18	1	18	7	126	6.3	12.6	$6,529.89

Review siting requirements study for Eb k	24	1	24	4	96	4.8	9.6	$4,975.16

Subtotal



	683	34.15	68.3	$36,556.12

TOTAL ANNUAL BURDEN AND COST

(rounded)





785.45

785 (rounded)

$36,556



Assumptions:

a.  We have estimated that an average of 12 sources are subject to
subparts Ea and Eb.  Seven of these sources are currently subject to
subpart Ea, with no additional sources

becoming subject to the regulation in the next three years.  The
remaining five sources are subject to subpart Eb (4 existing and 1 new).
 We have assumed that one additional

source per year will become subject to the standard over the next three
years.  It is further assumed that there is an average of two affected
facilities per plant per respondent.

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses: $62.27 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21
Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate
(GS-6, Step 3, $15.63 x 1.6).  These rates are from the Office of
Personnel Management (OPM) 2011 General Schedule which excludes locality
rates of pay

c  It is estimated that respondents will take 12 hours once per year to
perform retest preparations and observance for subpart Eb.

d  We have assumed that only one respondent will be required to perform
report review for Eb.

e. It is estimated that 80 percent of respondents will review reports
for no excess emission for subpart Ea.

f  It is assumed that 20 percent of respondents will review reports for
excess emission for subpart Ea.

g.  We have assumed that all four respondents that are subject to
subpart EB will review semiannual excess emission reports.

h.  We have assumed that all seven respondents that are currently
subject to subpart Ea will have to review quarterly reports.

i  We have assumed that all four respondents that are subject to subpart
Eb will have to review annual compliance reports.

j  We have assumed that it will take 18 hours to review the annual
compliance test for Ea.

k  All of the four respondents that are subject to subpart Eb will have
to review the siting requirement’s study.



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