                             SUPPORTING STATEMENT
                        ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

1.  Identification of the Information Collection

      1(a)  Title of the Information Collection

Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60,     Subpart FFFF) (Renewal), EPA ICR Number 2164.04, OPM Control Number 2060-0562

      1(b)  Short Characterization/Abstract

      Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) were proposed on December 9, 2004 (69 FR 71471), promulgated on December 16, 2005 (70 FR 74892), and amended on November 24, 2006 (71 FR 67806).  The regulated OSWI units include two subcategories: very small municipal waste combustion (VSMWC) units that combust less that 35 tons per day of waste and institutional waste incineration (IWI) units. This standard applies to any air quality program in a state or United States protectorate with one or more existing other solid waste incineration (OSWI) units or air curtain incinerators that commenced construction on or before December 9, 2004.  This subpart does not directly affect incineration unit owners and operators; however, they must comply with the state's plan that was developed by the air quality program administrator to implement the emission guidelines.  This information is being collected to assure compliance with 40 CFR part 60, subpart FFFF. 
      
      In general, all New Source Performance Standards (NSPS) require initial notifications, performance tests, one-time and periodic reports.  They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative.  These notifications, reports and records are essential in determining compliance, and are required of all affected facilities subject to the NSPS. 
      
      Any owners or operators subject to the provisions of this part shall 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.  All reports are sent to the delegated state or local authority.       In the event that there is no such delegated authority, the reports are sent directly to the U. S. Environmental Protection Agency (EPA) regional office.

      Over the next three years, an average of 99 respondents per year will be subject to the standard, and no additional respondents will become subject to the standard.  This standard applies to OSWI units that commenced construction on or before December 9, 2004.  Therefore, there will be no new units constructed during the period covered by this ICR.
      
      The Office of Management and Budget (OMB) approved the currently active ICR without any "Terms of Clearance."
      
      All of the other solid waste incineration (OSWI) units in the United States, are owned and operated by the solid waste incineration industry (the "Affected Public").  However, this ICR applies directly to the emission guidelines with most of the units regulated by either, state, local, tribal or the Federal government.  They are considered not-for-profit businesses.  The burden to the "Affected Public" is listed below in Table 1: Annual Respondent Burden and Cost − Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).  The Federal government burden associated with the review of reports submitted by the respondent is shown below in Table 2: Average Annual EPA Burden and Cost  -  Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (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; . . . .

      In the Administrator's judgment, pollutant emissions from other solid waste incineration units cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare.  Therefore, the emission guidelines were promulgated for this source category   at 40 CFR part 60, subpart FFFF.

      2(b)  Practical Utility/Users of the Data

      The recordkeeping and reporting requirements in the standard ensure compliance            with the applicable regulations, which were promulgated in accordance with the Clean                   Air Act.  The collected information is used also 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 standards are being met.  The performance test may also be observed.
      
      The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

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

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

      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, duplication does not 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 has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years.  The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS), which is operated and maintained by the EPA Office of Compliance.  OTIS is EPA's database for the collection, maintenance, and retrieval of all compliance data.  The growth rate for the industry is based on our consultations with the Agency's internal industry experts.  

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      Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes.  In developing this ICR, we contacted: 1) the National Solid Waste Management Association (NSWMA), at (202) 364-3773; and 2) the Solid Waste Association of North America (SWANA), at (240) 494-2253. EPA did not receive any comments from the consultations. 
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      It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice.  
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      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 were 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 established by OMB at 5 CFR part 1320, section 1320.5.
 	
      These standards require the respondents to maintain all records, including reports and notifications for at least five years.  This is consistent with the General Provisions as applied to the standards.  EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based.  The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action.  EPA has found that the most flagrant violators have violations extending beyond the five years.              In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

      3(f)  Confidentiality
      
      Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
      
      3(g)  Sensitive Questions
      
      The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4.  The Respondents and the Information Requested

      4(a)  Respondents/SIC Codes

      The respondents to the recordkeeping and reporting requirements are other solid waste incineration units.  The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, which correspond to the North American Industry Classification System (NAICS) codes, are listed in the following table.

                   Standard (40 CFR, part 60, subpart FFFF)
                                   SIC Codes
                                  NAICS Codes
Solid Waste Combustors and Incinerators
                                     4953
                                    562213
Administration of Air and Waste Resource and Solid Waste Management Programs
                                     9511
                                    924110
Nursing and Residential Care Facilities
                            8051, 8052, 8059, 8361
                                      623
Justice, Public Order, and Safety Activities
                   9211, 9221, 9222, 9223,  9224, 9229, 8322
                                      922
National Security and International Affairs
                                  9711, 9721
                                      928
Elementary and Secondary Schools
                                     8211
                                    611110
Junior Colleges
                                     8222
                                    611210
Colleges, Universities, and Professional Schools
                                     8221
                                    611310
Museums, Historical Sites, and Similar Institutions
                               8412, 8422, 7999
                                     7121
Religious Organizations
                                     8661
                                    813110
Civic and Social Organizations
                                  8641, 8699
                                    813410
      4(b)  Information Requested

            (i)  Data Items

      In this ICR, all the data recorded or reported is required by the Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF).
      
      A source must make the following reports:
      
                                 Notifications
Waste management plan
60.3010, 60.3011, 60.3012
Notification of operating limit deviation report
60.3052 and 60.3053
Notification of deviation
60.3054(a)(1)
Notification of status report
60.3054(a)(2)
Notification of resumed operation
60.3054(b)

                                    Reports
Initial performance test and report
60.3049, 60.8(a)
Annual compliance test report
60.3050, 60.3053
Semiannual report of deviation
60.3052

      A source must keep the following records:

                                Recordkeeping 
Maintain records of all test reports 
60.3068(a)
Records are required to be retained for five years
60.3068(e)
Maintain waste management plan records
60.3010

Electronic Reporting

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      Some of the respondents are using monitoring equipment that automatically records parameter data.  Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.
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      Also, regulatory agencies, in cooperation with the respondents continue to create reporting systems to transmit data electronically.  However, electronic reporting systems are not widely used.  At this time, it is estimated that 10 per	cent of the respondents use electronic reporting.
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            (ii)  Respondent Activities

                             Respondent Activities
Read instructions.
Install, calibrate, maintain, and operate a coil coating line at their metal coil surface coating plants.
Perform initial performance test, Reference Methods, 3A, 3B, 26A tests, and repeat performance tests if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.
Adjust the existing ways to comply with any previously applicable instructions and requirements.
Train personnel to be able to respond to a collection of information.
Transmit, or otherwise disclose the information.

	Currently, sources are using monitoring equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring system).  Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.

5.  The Information Collected: Agency Activities, Collection Methodology, and Information Management

      5(a)  Agency Activities

      EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

                               Agency Activities
Observe initial performance tests and repeat performance tests if necessary.
Review notifications and reports, including performance test reports, 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 could 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 EPA's 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 five years.
      
      5(c)  Small Entity Flexibility

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      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 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 Respondent Burden and Cost − Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (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 70,132 (Total Labor Hours from Table 1 below).  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 	$121.42 ($57.82 + 110%)
            Technical	$99.14 ($47.21 + 110%)
            Clerical	$49.81 ($23.27 + 110%)
      
These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 "Table 2: Civilian Workers, by occupational and industry group."  The rates are from column 1, "Total Compensation."  The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

            (ii)  Estimating Capital/Startup and Operation and Maintenance Costs
            
      The type of industry costs associated with the information collection activities in the subject 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)
Continuous emission monitoring system 
                                    $44,445
                                       0
                                      $0
                                    $5,000
                                      99
                                   $495,000



                                      $0


                                   $495,000

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

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      The total operation and maintenance (O&M) costs are $495,000.  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 $495,000.

      6(c)  Estimating Agency Burden and Cost

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      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.
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      The average annual Agency cost during the three years of the ICR is estimated to be $389,912.
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      This cost is based on the average hourly labor rate as follows:
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            Managerial	$62.27   (GS-13, Step 5, $38.92 + 60%)
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            Technical	$46.21   (GS-12, Step 1, $28.88 + 60%)
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            Clerical	$25.01   (GS-6, Step 3, $15.63 + 60%)
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      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 below in Table 2: Average Annual EPA Burden and Cost − Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).
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      6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Based on our research for this ICR, on average over the next three years, approximately 99 existing respondents will be subject to the standard.  It is estimated that no additional respondents per year will become subject to the standard.  The average number of respondents, as shown in the table below, is 99 per year. 

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






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Number of Respondents
--------------------------------------------------------------------------------
Year
--------------------------------------------------------------------------------
(A)
--------------------------------------------------------------------------------
Number of New Respondents [1]
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(B)
--------------------------------------------------------------------------------
Number of Existing Respondents
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(C)
--------------------------------------------------------------------------------
Number of Existing Respondents That Keep Records But Do Not Submit Reports
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(D)
--------------------------------------------------------------------------------
Number of Existing Respondents That Are Also New Respondents
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(E)
--------------------------------------------------------------------------------
Number of Respondents
--------------------------------------------------------------------------------
(E=A+B+C-D)
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1
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
--------------------------------------------------------------------------------
2
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
--------------------------------------------------------------------------------
3
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
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Average
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
99
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      [1] New respondents include sources with constructed, reconstructed and modified affected facilities.
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      Column D is subtracted to avoid double-counting respondents.  As shown above, the average Number of Respondents over the three-year period of this ICR is 99.
      
      The total number of annual responses per year is calculated using the following table:
      
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Total Annual Responses
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(A)
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Information Collection Activity
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(B)
--------------------------------------------------------------------------------
Number of Respondents
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(C)
--------------------------------------------------------------------------------
Number of Responses
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(D)
--------------------------------------------------------------------------------
Number of Existing Respondents That Keep Records But Do Not Submit Reports
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(E)
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Total Annual Responses
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E=(BxC)+D
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Notification of final compliance
--------------------------------------------------------------------------------
82.7
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0
--------------------------------------------------------------------------------
0
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0
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Initial compliance report
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82.7
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0
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
0
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Waste management plan
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82.7
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0
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0
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0
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Annual compliance reports
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99
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2
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0
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198 
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Semiannual deviation reports
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99
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1
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0
--------------------------------------------------------------------------------
99
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Total
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297
      
      The number of Total Annual Responses is 297.
      
      The total annual labor costs are $6,720,028.  Details regarding these estimates will be found below in Table 1: Annual Respondent Burden and Cost − Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).
      
      6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables
      
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      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. 
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            (i)  Respondent Tally

      The total annual labor hours are 70,132, at a cost of $6,720,028.  Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost − Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).  
      
      Furthermore, the annual public reporting and recordkeeping burden for this collection       of information is estimated to average 236 hours per response.
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      The total annual capital/startup and O&M costs to the regulated entity are $495,000.       The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.
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            (ii)  The Agency Tally
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      The average annual Agency burden and cost over next three years is estimated to be 8,653 labor hours, at a cost of $389,912.  See below Table 2: Average Annual EPA Burden and Cost − Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).
      
      6(f)  Reasons for Change in Burden

      There is a decrease in the total estimated burden for both the respondents and the Agency from the most recently approved ICR due to a decrease in the number of sources.  At the time of rule promulgation, EPA estimated that 248 respondents were subject to the standard.  However, many facilities have shut down or ceased operation since 2005.  In recent years in support of potential OSWI regulatory development, the Agency consulted with internal data experts and conducted data and permits searches to inventory the number of existing OSWI units. The data collection activities in 2010 suggest that only 99 VSMWC and IWI sources are subject to the standard.  This represents an approximately 60 percent decrease in the respondent universe since 2005. 
      
      The decrease in the respondent universe also results in significant reduction of the overall O&M costs to the respondents. 
      
      Additionally, this ICR corrects a mathematical error in the previous ICR's estimate for the respondent recordkeeping burden. 
      
      6(g)  Burden Statement

      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 236 hours per response.  Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, 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.
      
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      An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number.  The OMB Control Numbers for EPA's regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2011-0256.  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 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, DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.                      The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Enforcement and Compliance Docket and Information Center Docket 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, DC 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0256 and OMB Control Number 2060-0562 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 Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

                                  Burden item
                                      (A)
                          Person hours per occurrence
                                      (B)
                  No. of occurrences per respondent per year
                                      (C)
                     Person hours per respondent per year
                                    (C=AxB)
                                      (D)
                           Respondents 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)
                                  Total Cost 
                                  Per year b

1.  Applications
                                      N/A

                                       
                                       
                                       
                                       
                                       
                                                                               
2.  Survey and Studies
                                      N/A

                                       
                                       
                                       
                                       
                                       
                                                                               
3.  Reporting requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     A.  Read instructions [c]
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                             $0
     B.  Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
        1)  Initial performance test and reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
             a)  Initial performance tests and test reports
             (PM, dioxins/furans, opacity, fugitives,
             HCI, Cd, Pb, Hg) [c, d]
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                                                             $0
             b) Repeat of initial performance tests [d, e]
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                                                             $0
        2)  CEMS demonstration (CO, 02)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
             a) Repeat of initial demonstration [e]
                                      229
                                       1
                                      229
                                       0
                                       0
                                       0
                                       0
                                                                             $0
        3)  Annual performance tests and test reports
             (PM, dioxins/furans, opacity, fugitives,
             HCI, Cd, Pb, Hg) 
                                      24
                                       1
                                      24
                                      99
                                     2,376
                                     118.8
                                     237.6
                                                                   $261,819.28 
        4)  Quarterly Appendix F audits of CEMS 
             (CO)                     
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
             a)  RATA audit (one per year) [f]
                                       4
                                       1
                                       4
                                      99
                                      396
                                     19.8
                                     39.6
                                                                    $43,636.55 
             b)  RAA audit (three per year) [f]
                                       4
                                       3
                                      12
                                      99
                                     1,188
                                     59.4
                                     118.8
                                                                   $130,909.64 
             c)  Daily calibration and operation [f, g]
                                       1
                                      250
                                      250
                                      99
                                    24,750
                                    1,237.5
                                     2,475
                                                                 $2,727,284.18 
     C.  Create information
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     D.  Gather information
                                    See 3E
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     E.  Report preparation
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
           1)  Contract or secure alternative means of 
           disposal  [d]
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                             $0
           2)  Notification of final compliance [c, d]
                                      1.5
                                       1
                                      1.5
                                       0
                                       0
                                       0
                                       0
                                                                             $0
           3)  Initial compliance report [c, d]
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                             $0
           4)  Waste management plan [c, d]
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                             $0
           5)  Annual compliance reports 
                                      40
                                       1
                                      40
                                      99
                                     3,960
                                      198
                                      396
                                                                   $436,365.47 
           6)  Semiannual deviation reports
                                      24
                                       2
                                      48
                                      99
                                     4,752
                                     237.6
                                     475.2
                                                                   $523,638.56 
Subtotal for Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                   43,035.3
                                       
                                                                               
4.  Recordkeeping requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     A.  Read instructions 
                                    See 3A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     B.  Plan activities
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     C.  Implement Activities 
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     D.  Develop record system
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     E.  Record information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
          1)  Records of SSM [h]
                                      1.5
                                      52
                                      78
                                      99
                                     7,722
                                     386.1
                                     772.2
                                                                   $850,912.66 
          2)  Records of emission rate computations,
          all emission exceedances and periods when
          there is no data [h]
                                      1.5
                                      52
                                      78
                                      99
                                     7,722
                                     386.1
                                     772.2
                                                                   $850,912.66 
         3)  Records of employee review of operations
         manual 
                                       4
                                       1
                                       4
                                      99
                                      396
                                     19.8
                                     39.6
                                                                    $43,636.55 
         4)  Record of control devices operating 
          parameters [h]
                                      1.5
                                      52
                                      78
                                      99
                                     7,722
                                     386.1
                                     772.2
                                                                   $850,912.66 
     F. Personnel training
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
    G. Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
Subtotal  for Recordkeeping Requirements  
                                       
                                       
                                       
                                       
                                   27,096.3
                                                                               





                                    60,984
                                    3,049.3
                                    6,098.4
                                                                               
TOTAL LABOR BURDEN AND COST (rounded)




                                       
70,132
                                                                     $6,720,028

Assumptions:
[a]  We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.  
[b]  This ICR uses the following labor rates:  $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per hour for Clerical labor.  These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 "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.
[c]  We have assumed that this is a one-time only cost.
[d]  This is the fifth year when a respondent will have reached the compliant date for the emission guidelines.
[e]  We have assumed that 20 percent of respondents will repeat initial tests due to failure.
f  We have assumed that RATA audits are performed for one of the four quarterly audits, and RAA tests are performed for three of the four quarterly audits.
g  We have assumed that each operation day requires a CEMS calibration; Combustor models 2, 3, and 4 assume 250 days of operation per year, Model 1 = 121 days/yr.  For consistency, 250 operating days are assumed for all models.  Emission testing hours (0.25 hr/occurrence) accounts for periodic contractor operation and maintenance support.  Annual hours averaged to a daily basis.
h  We have assumed that each respondent will record information 52 times per year.


























Table 2:  Average Annual EPA Burden and Cost  -  Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

                                   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]
1.  Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
2.  Read and understand rule requirements
                                      16
                                       1
                                      16
                                       0
                                       0
                                       0
                                       0
                                                                             $0
3.  Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     A.  Create information
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     B.  Gather information
                               See 3A &  3F
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     C.  Report reviews
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
          1) Notification of final compliance [c]
                                      1.5
                                       1
                                      1.5
                                       0
                                       0
                                       0
                                       0
                                                                             $0
          2) Review initial compliance test report [c]
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                             $0
          3) Review annual compliance report 
                                      40
                                       1
                                      40
                                      99
                                     3,960
                                      198
                                      396
                                                                    $205,216.70
          4) Review semiannual deviation reports
                                      16
                                       2
                                      32
                                      99
                                     3,168
                                     158.4
                                     316.8
                                                                    $164,173.36
          5)  Review waste management plan [c]
                                      16
                                       1
                                      16
                                       0
                                       0
                                       0
                                       0
                                                                          $0.00
     D.  Annual summary report [d]
                                       4
                                       1
                                       4
                                      99
                                      396
                                     19.8
                                     39.6
                                                                     $20,521.67
TOTAL ANNUAL BURDEN AND COST
 (rounded)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                     8,653
                                                                       $389,912

--------------------------------------------------------------------------------
 	Assumptions:
 a   We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.  For the purpose of the burden calculation, we are averaging the number of respondents over the three years period of this ICR.  In year two and three of this ICR all respondents will have reached the compliant date for the emission guidelines, which is five years after promulgation.
[b]  This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (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]  We have assumed that this is a one-time only cost.
[d] We have assumed that all affected facilities in the states will be required to prepare an annual summary plan.
Designated Administrator refers to the person indicated by each State plan as the compliance authority or to the USEPA Administrator in the event that a Federal
plan must be developed. 
