Supporting
Statement
for
EPA
Information
Collection
Request
#
1773.05
(
OMB
Control
#
2050­
0171)

Amendments
to
the
Reporting
and
Recordkeeping
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Hazardous
Waste
Combustors;
Direct
Final
Rule
October
2001
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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2
2(
a)
Need
and
Authority
for
the
Collection
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2
2(
b)
Practical
Utility/
Users
of
the
Data
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2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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2
3(
a)
Nonduplication
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2
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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2
3(
c)
Consultations
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2
3(
d)
Effects
of
Less
Frequent
Collection
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3
3(
e)
General
Guidelines
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3
3(
f)
Confidentiality
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3
3(
g)
Sensitive
Questions
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3
4.
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
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3
4(
a)
Respondents/
NAICS
Codes
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3
4(
b)
Information
Collected
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4
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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8
5(
a)
Agency
Activities
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8
5(
b)
Collection
Methodology
and
Management
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9
5(
c)
Small
Entity
Flexibility
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9
5(
d)
Collection
Schedule
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9
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
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9
6(
a)
Estimating
Respondent
Burden
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9
6(
b)
Estimating
Respondent
Cost
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10
6(
c)
Estimating
Agency
Burden
Cost
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10
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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10
6(
e)
Bottom
Line
Burden
Hour
and
Cost
Tables
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13
6(
f)
Reasons
for
Change
in
Burden
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13
6(
g)
Burden
Statement
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13
1
The
four
amendments
that
received
adverse
comment
included:
the
amendments
to
§
63.1201(
a)
and
§
63.1206(
b)(
13)(
i)
(
alternative
hydrocarbon
monitoring
location
for
short
cement
kilns
burning
hazardous
waste
at
locations
other
than
the
"
hot"
end
of
the
kiln);
the
amendments
to
§
63.1206(
b)(
6)(
i),
§
63.1206(
b)(
7)(
i)(
B),
§
63.1206(
b)(
7)(
ii)(
B),
and
§
63.1207(
c)(
2)(
i)
(
use
of
destruction
and
removal
efficiency
data
in
lieu
of
testing);
the
amendments
to
§
63.1206(
c)(
7)(
ii)
(
deletion
of
baghouse
inspection
requirements);
and
amendments
to
§
63.1207(
f)(
1)(
ii)
(
feedstream
analysis
for
organic
hazardous
air
pollutants).

1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
titled
"
Amendments
to
the
Reporting
and
Recordkeeping
Requirements
for
National
Emission
Standards
(
NESHAP)
for
Hazardous
Air
Pollutants
from
Hazardous
Waste
Combustors;
Direct
Final
Rule"
ICR
#
1773.05
(
OMB
Control
#
2050­
0171).

1(
b)
Short
Characterization/
Abstract
On
July
3,
2001,
EPA
published
a
direct
final
rule
(
66
FR
35087)
and
a
notice
of
proposed
rulemaking
(
66
FR
35124)
promulgating
and
proposing
thirteen
amendments
to
provisions
dealing
largely
with
rules
affecting
implementation
of
the
National
Emission
Standards
for
Hazardous
Waste
Combustors
(
subpart
EEE
of
Part
63).
For
the
purposes
of
this
ICR,
hazardous
waste
combustors
(
HWCs)
include
hazardous
waste
burning
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns.
EPA
indicated
that
it
was
promulgating
these
amendments
as
direct
final
rules
because
it
believed
the
amendments
to
be
non­
controversial.
However,
the
Agency
further
stated
that
if
we
received
adverse
comment
by
August
17,
2001
on
one
or
more
distinct
provisions
of
the
direct
final
rule,
we
would
publish
a
timely
withdrawal
of
those
distinct
provisions
in
the
Federal
Register,
and
deal
with
those
provisions
as
proposed
rules.
We
subsequently
received
adverse
comment
on
four
of
the
thirteen
provisions.
1
Thus,
the
nine
provisions
for
which
we
did
not
receive
adverse
comment
will
become
effective
on
October
16,
2001
as
provided
in
the
July
3,
2001
direct
final
rule.
This
ICR
removes
the
incremental
recordkeeping
and
reporting
burden
associated
with
the
four
amendments
that
were
withdrawn.

The
existing
paperwork
burden
for
the
final
rule
was
approved
in
EPA
ICR
Request
#
1773.02
"
New
and
Amended
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutant
from
Hazardous
Waste
Combustors,"
and
later
modified
by
EPA
ICR
Request
#
1773.03.

This
ICR
estimates
the
additional
(
incremental)
recordkeeping
and
reporting
burden
for
the
four
withdrawn
amendments
described
in
this
action:


The
recordkeeping
and
reporting
requirements
of
the
four
withdrawn
amendments
decrease
the
burden
to
the
regulated
community
by
2
hours
per
year
at
a
total
labor
cost
of
$
83
per
year.
This
recordkeeping
and
reporting
burden
reduction
is
incremental
to
the
burden
approved
under
EPA
ICR
Request
#
1773.03.


In
addition,
the
withdrawn
amendments
will
save
EPA
an
additional
124
hours
per
year
to
review
and
respond
to
the
required
submissions
at
a
cost
savings
of
$
3,447
per
year.
2
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
EPA
promulgated
revised
standards
for
hazardous
waste
combustors
under
joint
authority
of
the
Clean
Air
Act
and
Resource
Conservation
and
Recovery
Act.
See
64
FR
52828
(
September
30,
1999).
The
standards
limit
emissions
of
chlorinated
dioxins
and
furans,
other
toxic
organic
compounds,
toxic
metals,
hydrochloric
acid,
chlorine
gas,
and
particulate
matter.
These
standards
reflect
the
performance
of
Maximum
Available
Control
Technology
(
MACT)
as
specified
under
Section
112
of
the
Clean
Air
Act.

Certain
records
and
reports
are
required
to
ensure
that
the
standards
are
being
achieved
on
a
continuous
basis.
These
amendments
are
estimated
to
increase
the
recordkeeping
and
reporting
burden.

2(
b)
Practical
Utility/
Users
of
the
Data
The
data
collected
for
new
and
existing
HWC
system
operations
and
testing
are
used
by
facility
owners
and
operators
and
EPA
or
the
implementing
agency.
Data
maintained
in
records
are
used
to
monitor
results
of
testing,
inspections,
and
the
operation
of
air
pollution
control
systems,
as
well
as
to
demonstrate
compliance
with
regulations.
Notifications
and
submitted
monitoring
data
are
used
by
EPA
or
the
implementing
agency
to
evaluate
construction
/
reconstruction
plans,
test
and
operating
plans,
test
results,
facility
operation,
and
whether
facilities
qualify
for
certain
exemptions
and
alternative
monitoring
/
testing
methods.
EPA
also
requires
notification
procedures
to
ensure
stakeholder
involvement.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
collections
covered
in
this
ICR
are
not
available
from
sources
other
than
individual
respondents.
EPA's
Office
of
Solid
Waste
is
the
only
office
within
the
Agency
collecting
this
information,
and
no
other
Federal
agency
or
department
collects
this
information.
In
addition,
the
Office
of
Solid
Waste
has
systematically
reorganized
its
ICR
structure
to
eliminate
gaps
or
duplication.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
is
issuing
a
public
notice
in
the
Federal
Register
concerning
the
submittal
of
this
ICR
to
the
Office
of
Management
and
Budget
(
OMB)
and
its
availability
to
the
public
for
comment.
This
notice
is
contained
in
a
paragraph
of
the
direct
final
rule
Federal
Register
notice.

3(
c)
Consultations
The
direct
final
rule
amendments
covered
by
this
ICR
will
be
promulgated
using
proper
rulemaking
procedures.
EPA
has
made
efforts
to
consult
with
the
respondent
stakeholders,
general
public,
State
and
industry
officials,
and
the
appropriate
Federal
agencies
in
the
development
of
the
burden
estimates
for
this
(
and
previous
related)
ICRs.
3
EPA
has
worked
and
consulted
directly
with
the
respondent
stakeholders
and
trade
group
associations
when
developing
these
amendments,
and
that
these
amendments
are
a
direct
result
of
comments
from
and
meetings
with
the
impacted
respondents.

3(
d)
Effects
of
Less
Frequent
Collection
EPA
has
carefully
considered
the
burden
imposed
upon
the
regulated
community
by
hazardous
waste
combustion
regulations
and
the
potential
environmental
consequences
of
reducing
the
information
collection
frequencies.
Consequently,
EPA
is
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
minimize
the
burden
imposed.
EPA
believes
that,
if
the
minimum
requirements
specified
under
the
regulations
are
not
met,
EPA
will
be
unable
to
fulfill
its
Congressional
mandate
under
the
Resource
Conservation
and
Recovery
Act
and
Section
112
of
the
Clean
Air
Act.
In
addition,
efforts
were
made
to
integrate
the
monitoring,
compliance
testing,
and
recordkeeping
requirements
of
the
CAA
and
RCRA
so
that
facilities
will
be
able
to
avoid
duplicity
of
two
potentially
different
regulatory
compliance
schemes.

3(
e)
General
Guidelines
This
ICR
adheres
to
the
guidelines
stated
in
the
1995
Paperwork
Reduction
Act
as
amended,
OMB's
implementing
regulations,
OMB's
Information
Collection
Review
Handbook
(
EPA,
April
1998),
and
other
applicable
OMB
guidance.

It
is
necessary
for
facilities
to
retain
records
for
five
years
in
order
for
EPA
to
ensure
compliance
with
the
regulations.
The
recordkeeping
burden
for
such
a
requirement
is
not
significant.

3(
f)
Confidentiality
Section
3007(
b)
of
RCRA
and
40
CFR
Part
2,
Subpart
B,
which
define
EPA's
general
policy
on
the
public
disclosure
of
information,
contain
provisions
for
confidentiality.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.

4.
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
4(
a)
Respondents/
NAICS
Codes
The
following
lists
North
American
Industry
Classification
System
(
NAICS)
codes
associated
with
the
facilities
most
likely
to
be
affected
by
this
ICR:

NAICS
Industry
Type
2123
Nonmetallic
Mineral
Mining
2211
Electric
Power
Generation
22132
Sewage
Treatment
Facilities
3241
Petroleum
and
Coal
Products
3271
Clay
Product
and
Refractory
3231
Printing
and
Related
Support
3251
Basic
Chemical
Manufacturing
3252
Resin,
Synthetic
Rubber,
and
Plastic
4
3253
Pesticide
and
Fertilizer
3254
Pharmaceutical
and
Medicine
3255
Paint,
Coating,
and
Adhesive
3259
Other
Chemical
Products
3271
Concrete
Block
and
Brick
3273
Cement
and
Concrete
Product
3274
Lime
and
Gypsum
Product
3279
Other
Nonmetallic
Mineral
3327
Machine
Shops;
Turned
Product
3328
Coating,
Engraving,
Heat
3329
Other
Fabricated
Metal
Product
3332
Industrial
Machinery
3335
Metalworking
Machinery
3339
Other
General
Purpose
Equipment
Manufacturing
3341
Computer
and
Peripheral
3342
Communications
Equipment
3343
Audio
and
Video
Equipment
3344
Semiconductor
3361
Motor
Vehicle
Manufacturing
3362
Motor
Vehicle
Body
and
Trailer
3363
Motor
Vehicle
Parts
4227
Petroleum
Wholesalers
45431
Fuel
Dealers
5622
Waste
Treatment
and
Disposal
5629
Remediation
and
Other
Waste
4(
b)
Information
Collected
A.
Below
is
a
description
of
the
nine
amendments
included
in
EPA
ICR
Request
#
1773.03
that
are
not
impacted
by
the
withdrawal
action.

1.
Hazardous
Waste
Residence
Time
EPA
is
modifying
the
definition
of
hazardous
waste
residence
time
so
that
recycled
hazardous
waste­
derived
materials
should
not
be
considered
when
calculating
hazardous
waste
residence
time
(
§
63.1201(
a)).

(
i)
Data
items,
including
recordkeeping
requirements
The
comprehensive
performance
test
workplan
must
discuss
procedures
for
determining
the
hazardous
waste
residence
time.

(
ii)
Respondent
activity
None.

2.
Deletion
of
One­
Time
Notification
of
Compliance
with
Alternative
Clean
Air
Act
Standards
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
deleting
the
requirement
to
submit
a
one­
time
notification
of
compliance
that
would
have
5
been
used
to
alert
regulatory
officials
that
a
source
wants
the
option
of
complying
with
otherwise
applicable
MACT
standards
after
the
hazardous
waste
residence
time
has
expired
(
§
63.1206(
b)(
1)(
ii)).

(
ii)
Respondent
activity
Facilities
will
no
longer
have
to
submit
the
one­
time
notice
to
the
Agency.

3.
Time
Extension
for
Waiving
PM
and
Opacity
Standards
to
Correlate
PM
CEMS
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
allowing
a
waiver
of
the
particulate
matter
(
PM)
and
opacity
standards
during
PM
CEMS
correlation
tests
beyond
96
hours
if
approved
by
the
Administrator.

(
ii)
Respondent
activity
Sources
can
choose
to
submit
a
request
to
the
Administrator,
most
likely
as
part
of
the
performance
test
workplan,
for
an
extension
to
the
96
hour
waiver
of
the
particulate
matter
and
opacity
standards.

4.
Alternative
to
the
PM
Standard
for
Incinerators
Feeding
Low
Levels
of
Metals
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
revising
the
"
alternative
particulate
matter
(
PM)
standard"
option
of
the
final
rule.
Specifically,
the
final
rule
alternative
particulate
matter
standard
will
be
replaced
with
alternative
requirements
that
include:
(
1)
90%
semivolatile
metals
system
removal
efficiency
demonstrated
during
the
comprehensive
performance
testing;
(
2)
semivolatile
and
low
volatility
metals
emission
limitations
(
including
the
non­
enumerated
metals
HAPs
of
Co,
Ni,
Mg,
and
Se)
also
must
be
achieved
during
performance
testing;
and
(
3)
semivolatile
and
low
volatility
metals
feedrate
limitations
must
be
achieved
in
both
the
hazardous
waste
and
total
feedstreams
(
including
nonenumerated
HAPs)
on
a
12­
hour
average
basis
(
as
required
by
the
final
rule).
Sources
electing
to
comply
with
these
alternative
requirements
do
not
have
to
meet
the
0.015
gr/
dscf
particulate
matter
standard;
instead
they
remain
subject
to
the
RCRA
particulate
matter
standard
of
0.08
gr/
dscf.

(
ii)
Respondent
activity
As
part
of
the
comprehensive
performance
test
work
plan,
incinerator
facilities
may
request
the
option
of
complying
with
the
alternative
particulate
matter
standard.

Demonstration
of
compliance
with
the
alternative
to
the
particulate
matter
standard
requires:
(
1)
the
evaluation
of
semivolatile
metals
system
removal
efficiency
and
semi­
and
low
volatile
metals
emissions
levels
(
including
the
non­
enumerated
metals)
during
the
comprehensive
performance
test,
(
2)
measurement
of
particulate
matter
emissions,
and
(
3)
documentation
of
metals
feed
rates
from
all
feedstreams
(
including
non­
enumerated
metals)
on
a
daily
basis.

5.
Revisions
to
the
Metals
Feedrate
Extrapolation
Procedures
(
i)
Data
items,
including
recordkeeping
requirements
6
The
final
rule
currently
requires
documentation
that
the
levels
of
metal
spiking
assure
that
any
extrapolation
procedures
are
as
accurate
and
precise
as
if
no
extrapolations
were
used.
See
§
63.1207(
f)(
1)(
x)(
C).
This
is
being
modified
to
require
documentation
that
an
extrapolation
procedure
adequately
assures
compliance
with
the
emission
standards.

(
ii)
Respondent
activity
If
using
extrapolation
to
set
metals
feed
limits,
the
performance
test
workplan
must
include
justification
that
the
extrapolation
procedure
assures
compliance
with
the
emissions
standards.
Note
that
there
will
be
no
additional
recordkeeping
and
reporting
activities
under
this
revision
compared
with
the
final
rule.

6.
Feedrate
Limits
for
Nondetectable
Constituents
(
i)
Data
items,
including
recordkeeping
requirements
The
final
rule
specifies
that
separate
"
non­
detect
feedrate
limits"
must
be
established
for
constituents
with
non­
detect
measurements
made
during
the
compliance
testing.
Under
this
approach,
feed
locations
that
have
"
non­
detect"
limits
could
not,
during
normal
operations,
feed
detectable
levels
of
the
constituent
unless
certain
criteria
is
met.
See
§
63.1207(
n).
EPA
is
eliminating
this
provision
for
identifying
feedrate
limits
and
replacing
it
with
a
provision
that
requires
the
source,
on
a
site­
specific
basis,
to
specify
a
method
to
be
used
to
account
for
nondetects
when
establishing
feedrate
limits.

(
ii)
Respondent
activity
Specify
in
the
performance
test
workplan
the
method
to
be
used
to
account
for
non­
detects
when
establishing
feedrate
limits.

7.
Revisions
to
Assist
Early
Compliance
EPA
is
eliminating
two
impediments
to
early
compliance
(
see
§
62.1207(
5)
and
§
63.1211(
d)).
First,
early
complying
sources
that
fail
the
comprehensive
performance
test
will
not
be
required
to
stop
burning
hazardous
waste.
Second,
early
complying
sources
will
be
exempt
from
the
Documentation
of
Compliance
requirements.

(
i)
Data
items,
including
recordkeeping
requirements
None.

(
ii)
Respondent
activity
None.

8.
Accuracy
Requirements
for
Weight
Measurement
Devices
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
eliminating
the
weight
measurement
device
accuracy
requirement
for
everything
except
carbon
injection
systems
and
requiring
sources
to
specify
an
appropriate
accuracy
requirement
for
each
device
in
the
continuous
monitoring
system
evaluation
test
plan.
7
(
ii)
Respondent
activity
The
continuous
monitoring
system
evaluation
plan
and
test
plan
will
continue
to
include
calibration
frequency,
accuracy
requirements,
and
procedures
for
all
measurement
and
monitoring
devices.

9.
Deletion
of
Requirement
for
Establishing
a
Scrubber
Liquid
Minimum
pH
Operating
Parameter
Limit
for
Mercury
Control
for
Wet
Scrubbers
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
deleting
the
requirement
to
establish
a
minimum
pH
limit
to
ensure
compliance
with
the
mercury
standard.

(
ii)
Respondent
activity
Deleting
the
minimum
pH
limit
for
mercury
control
is
not
likely
to
change
the
recordkeeping
and
reporting
activity
because
a
minimum
pH
limit
is
still
required
to
ensure
compliance
with
the
HCl
and
chlorine
gas
standard.

B.
Below
is
a
description
of
the
four
amendments
included
in
EPA
ICR
Request
#
1773.03
that
are
withdrawn.

1.
Use
of
DRE
Data
in
Lieu
of
Testing
(
i)
Data
items,
including
recordkeeping
requirements
Two
revisions
are
being
made
to
the
"
data­
in­
lieu"
provisions
­­
under
which
previous
testing
results
are
used
in
place
of
the
requirement
for
further
source
testing
(
§
63.1206(
6)­(
7)).
The
first
revision
eliminates
the
age
restriction
on
usable
destruction
and
removal
efficiency
(
DRE)
test
data.
The
second
revision
eliminates
the
requirement
that
specifies
that
in­
lieu
data
must
have
been
collected
for
the
purpose
of
RCRA
permit
issuance
or
re­
issuance.

(
ii)
Respondent
activity
If
a
source
chooses
to
submit
DRE
data
from
testing
for
a
purpose
other
than
RCRA
permit
issuance
or
reissuance
in
lieu
of
conducting
a
new
DRE
test,
the
source
must
document
that
the
quality
of
the
data
are
suitable
for
a
compliance
determination.

2.
Alternative
Hydrocarbon
Monitoring
Location
for
Short
Cement
Kilns
Burning
Hazardous
Waste
at
Locations
Other
Than
the
"
Hot"
End
of
the
Kiln
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
finalizing
an
alternative
hydrocarbon
standard,
and
in
limited
situations,
an
alternative
carbon
monoxide
standard
for
cement
kilns
that
continuously
monitor
hydrocarbon
both
in
the
bypass
duct
and
at
a
preheater
tower
combustion
gas
monitoring
location
(
§
63.1206(
13)(
b)(
i)).
Also,
a
new
definition
for
a
cement
kiln
preheater
tower
combustion
gas
monitoring
location
is
being
finalized
(
§
63.1201(
a)).

(
ii)
Respondent
activity
8
If
a
source
chooses
to
request
the
waiver
to
reduce
the
cost
of
compliance,
the
request
must
be
made
as
an
additional
item
in
the
comprehensive
performance
test
plan.

3.
Deletion
of
Baghouse
Inspection
Requirements
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
deleting
all
of
the
prescribed
baghouse
inspection
requirements
and
instead
relying
on
the
general
operation
and
maintenance
plan
requirements
under
§
63.1206(
c)(
7)(
i),
in
combination
with
the
bag
leak
detector,
to
ensure
proper
operation
and
maintenance
of
the
baghouse.
Thus,
the
operating
and
maintenance
plan
will
identify
site­
specific
inspection
intervals
for
baghouse
operations.

(
ii)
Respondent
activity
Recordkeeping
and
reporting
of
baghouse
monitoring
and
inspection
efforts
will
be
reduced
because
each
source
will
identify
site­
specific
monitoring
and
inspection
procedures
in
the
operation
and
maintenance
plan,
rather
than
complying
with
generic,
comprehensive
procedures.

4.
Feedstream
Analysis
for
Organic
HAPs
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
revising
the
rule
to:
(
1)
allow
less
comprehensive
organics
analysis
of
waste
streams
if
warranted
on
a
site­
specific
basis;
and
(
2)
require
organics
analysis
of
hazardous
waste
feed
streams
only.

(
ii)
Respondent
activity
On
a
site­
specific
basis,
facilities
will
identify
(
and
provide
rationale
for
selection)
which
feedstream
will
be
subject
to
characterization
of
organic
constituents.
This
site­
specific
plan
would
be
included
in
both
the
feedstream
analysis
plan
and
performance
test
plan.

The
revision
will
not
increase
the
actual
recordkeeping
and
reporting
activity
unless
a
source
chooses
to
request
less
comprehensive
analysis
of
waste
streams.
If
so,
the
source
must
document
in
the
test
plan
and
feedstream
analysis
plan
the
rationale
for
reduced
analysis.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
This
section
discusses
how
EPA
will
collect
the
information,
what
activities
EPA
will
perform
with
the
collected
information,
and
how
EPA
will
manage
the
information
it
collects.
This
section
also
discusses
how
the
information
collection
requirements
affect
small
entities.

5(
a)
Agency
Activities
Most
of
the
items
in
this
ICR
are
new
or
modified
provisions
allowing
affected
sources
to
request
or
petition
to
comply
with
alternative
approaches
that
generally
reduce
the
burden
of
the
final
rule.
In
many
cases,
these
requests
would
be
included
in
the
comprehensive
performance
test
9
plan,
continuous
monitoring
system
evaluation
plan
and
test
plan,
or
the
operating
and
maintenance
plan.
All
of
these
documents,
including
the
requests,
would
be
reviewed
and
approved
by
the
Agency.
Thus,
Agency
time
to
review
and
approve
these
documents
would
be
somewhat
increased
as
a
result
of
some
of
the
requirements
in
the
proposed
rule.
Section
6(
c)
below
shows
the
estimates
of
increased
Agency
burden
for
the
various
proposed
requirements.

5(
b)
Collection
Methodology
and
Management
Much
of
the
ICR
activity
is
comprised
of
reporting
requirements
that
will
be
submitted
by
mail
directly
to
the
Agency
for
review.

Also,
some
recordkeeping
information
will
also
be
kept
in
facility
files.
This
requires
the
implementing
authority
to
visit
and
collect
from
the
facility,
or
request
by
mail,
any
information
it
wishes
to
review.

Agency
management
of
collected
information
includes
review
of
information,
making
determinations,
and
filing
and
storing
information
collected.

In
collecting
and
analyzing
information
required
for
hazardous
waste
combustors,
EPA
uses
electronic
equipment,
including
telephone
systems,
personal
computers,
electronic
mail,
and
database
software,
as
necessary.

5(
c)
Small
Entity
Flexibility
EPA
identified
six
out
of
171
identified
combustion
facilities
as
small
entities.
EPA
conducted
an
incremental
assessment
of
any
cost
savings
or
cost
burdens
that
may
result
from
these
amendments
to
the
final
rule
on
the
small
entities.
Based
on
our
assessment,
the
Agency
concluded
that
there
will
not
be
any
significant
cost
burdens
or
cost
savings
across
all
the
small
business
facilities
for
any
of
the
amendments.
For
details
of
the
analysis,
see
Regulatory
Flexibility
Screening
Analysis
(
RFSA)
For
NESHAP:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors
(
May
2001)
and
Adjustments
to
the
Economic
Assessment
and
Regulatory
Flexibility
Screening
Analysis
in
Response
to
the
Withdrawal
of
Four
Amendments
Previously
Submitted
Under:
NESHAP:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors,
Direct
Final
Rule
(
October
4,
2001)
in
the
docket
to
this
rulemaking.

5(
d)
Collection
Schedule
Most
of
the
ICR
requirements
have
clearly
defined
reporting
schedules.
For
example,
test
plan
and
operating
and
maintenance
plans
are
required
to
be
submitted
in
a
intermittent,
but
well
defined
manner,
prior
to
compliance
testing
and
facility
operations.

Although
the
means
by
which
respondents
submit
the
information
is
not
specified,
it
should
be
submitted
to
the
Agency
as
paper
copies
and
computer
files
if
possible.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
Burden
estimates
are
based
on
recent
Information
Collection
Request
preparations
associated
with
the
HWC
MACT
final
rule
(
ICR
#
1773.02)
and
later
modified
by
ICR
#
1773.03.
These
involved
consultations
with
respondents
from
the
regulated
community,
general
public,
state
and
10
Federal
agencies.

6(
b)
Estimating
Respondent
Cost
Respondent
burden
hours
and
costs
associated
with
all
requirements
covered
by
this
ICR
are
shown
in
Exhibit
1
and
have
been
annualized
over
the
3
year
period
of
this
ICR.
Cost
estimate
assumptions
are
discussed
in
the
following
four
sections.

(
i)
Estimating
Labor
Costs
EPA
estimates
the
average
hourly
labor
cost
for
respondents
is
$
93.97
for
legal
staff,
$
71.49
for
managerial
staff,
$
55.00
for
technical
staff,
$
71.49
for
consultants
staff,
and
$
26.48
for
clerical
staff.
These
rates
are
based
on
the
Bureau
of
Labor
Statistics'
employment
cost
statistics,
and
have
been
updated
at
a
3%
inflation
index
to
current
year
dollars.
These
rates
are
also
consistent
with
the
rates
typically
paid
by
the
regulated
hazardous
waste
combustor
community.

(
ii)
Estimating
Capital
and
Operating
and
Maintenance
Costs
Capital
and
operating
and
maintenance
costs
include
submittal
of
information
and
notices
to
the
permitting
agency.
This
will
include
mailing
($
10.00
per
package
via
registered
mail)
and
photocopying
expenses
($
0.04
per
page).

(
iii)
Capital
/
Start­
Up
Costs
There
are
no
capital
/
start­
up
costs
associated
with
these
ICR
burdens.

(
iv)
Annualized
Capital
/
Start­
Up
Costs
One
time
costs
are
annualized
over
the
expected
length
of
the
equipment
lifetime.

6(
c)
Estimating
Agency
Burden
Cost
Agency
burden
hours
and
costs
associated
with
all
requirements
covered
by
this
ICR
are
shown
in
Exhibit
2.
Burden
is
due
to
increased
hours
to
review
and
approving,
if
necessary,
test
workplans,
petitions,
and
requests.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
estimated
burden
and
costs
discussed
in
this
section
represent
the
average
burden
and
cost
incurred
by
a
hazardous
waste
combustor
facility.
Actual
burden
for
each
facility
will
vary,
depending
on
the
number,
capacity,
and
complexity
of
the
combustion
units
at
the
facility.

(
i)
Universe
Determination
The
Agency
estimates
that
171
facilities
with
hazardous
waste
combustion
units
are
impacted
by
the
proposed
amendments.
This
includes
33
cement
kilns
at
18
sites,
10
lightweight
aggregate
kilns
at
5
sites,
26
commercial
incinerators
at
20
sites,
and
160
on­
site
incinerators
at
128
sites.

(
ii)
Activities
A.
Below
is
a
description
of
the
burden
of
the
nine
amendments
included
in
EPA
ICR
Request
#
1773.03
that
are
not
impacted
by
the
withdrawal
action.
11
0.
Familiarize
With
Rule
All
171
HWCs
will
read
the
rule.

1.
Hazardous
Waste
Residence
Time
There
are
no
additional
recordkeeping
or
reporting
burdens
associated
with
this
amendment.

2.
Deletion
of
One­
Time
Notification
of
Compliance
with
Alternative
Clean
Air
Act
Standards
The
deletion
of
a
one­
time
notification
of
compliance
with
alternative
MACT
standards
after
the
hazardous
waste
residence
time
has
expired
will
reduce
the
reporting
burden
of
the
final
rule
by
a
small
amount.

3.
Time
Extension
for
Waiving
PM
and
Opacity
Standards
to
Correlate
PM
CEMS
Because
it
is
anticipated
that
few
(
if
any)
units
will
choose
to
petition
the
Administrator
to
use
PM
CEMS,
there
will
be
no
burden
from
allowing
time
extensions
from
particulate
matter
and
opacity
standards
to
complete
correlating
PM
CEMS
based
on
a
written
request.

4.
Alternative
to
the
PM
Standard
for
Incinerators
Feeding
Low
Levels
of
Metals
It
is
projected
that
these
alternative
to
the
particulate
matter
(
PM)
standard
provisions
will
be
used
at
5
incinerator
facilities.
Testing,
reporting,
and
recordkeeping
burdens
associated
with
the
new
modified
alternative
particulate
matter
standard
are
very
similar
to
those
under
the
general
MACT
rule.
Minor
differences
include:
(
1)
the
alternative
particulate
matter
standard
requires
semivolatile
metals
system
removal
efficiency
testing
(
which
can
be
incorporated
in
the
standard
semivolatile
metals
testing,
thus
carries
no
additional
burden);
and
(
2)
the
additional
requirement
for
the
characterization
of
the
four
non­
enumerated
metals
(
Co,
Ni,
Mn,
and
Se)
in
the
feed
and
emissions
streams.

Note
additionally,
that
this
alternative
is
not
a
requirement,
but
rather
an
option
that
could
be
used
in
lieu
of
the
final
rule
particulate
matter
standard
requirements.
Overall,
it
is
projected
that
the
net
cost
burden
for
sources
using
this
alternative
will
be
significantly
reduced
because
of
the
cost
savings
as
a
result
of
reduced
requirements
to
upgrade
the
particulate
matter
air
pollution
control
system
(
reduced
as
a
result
of
complying
with
the
alternative
standard
requirements
compared
with
the
0.015
gr/
dscf
particulate
matter
standard).

5.
Revisions
to
the
Metals
Feedrate
Extrapolation
Procedures
There
are
no
additional
recordkeeping
or
reporting
burdens
associated
with
the
modifications
to
the
requirements
for
using
extrapolation
to
set
metals
feedrate
limits.

6.
Feedrate
Limits
for
Nondetectable
Constituents
Procedures
for
setting
feedrate
limits
must
be
contained
in
the
comprehensive
test
workplan.
It
is
estimated
that
25%
of
facilities
will
need
to
document
how
they
will
handle
non­
detected
constituents
when
determining
feedrate
limitations.
Each
request
is
estimated
to
take
0.5
hours
to
prepare.

7.
Revisions
to
Assist
Early
Compliance
12
Sources
that
elect
to
comply
early
will
not
be
required
to
submit
a
Documentation
of
Compliance,
thus
reducing
reporting
burden.
EPA
estimates
that
5%
of
sources
will
comply
early
and
will
not
have
to
prepare
and
submit
a
Documentation
of
Compliance.

8.
Accuracy
Requirements
for
Weight
Measurement
Devices
Sources
will
still
be
required
to
specify
an
appropriate
accuracy
requirement
for
weight
measurement
devices,
in
lieu
of
the
current
generic
requirement,
and
to
include
the
requirement
in
the
continuous
monitoring
system
evaluation
plan
and
test
plan.
Thus,
the
recordkeeping
and
reporting
activity
will
not
change.

9.
Revisions
to
Operating
Parameter
Limits
for
Wet
Scrubbers
The
elimination
of
the
minimum
pH
operating
limit
for
mercury
is
anticipated
to
have
no
significant
impact
on
recordkeeping
and
reporting
requirements
compared
with
those
of
the
final
rule.

B.
Below
is
a
description
of
the
burden
of
the
four
amendments
included
in
EPA
ICR
Request
#
1773.03
that
are
withdrawn.

1.
Use
of
DRE
Data
in
Lieu
of
Testing
The
rule
will
increase
the
potential
for
the
use
of
previous
testing
results
in
place
of
requirements
for
new
testing.
Thus,
it
will
reduce
the
need
for
new
testing.
Note
though,
the
direct
final
rule
will
not
reduce
the
recordkeeping
and
reporting
burden
of
the
final
rule
significantly
because
the
final
rule
ICR
assumed
that
existing
destruction
and
removal
efficiency
(
DRE)
data
will
be
allowable
for
confirmation
of
compliance
with
the
DRE
standard
for
most
all
facilities.

2.
Alternative
Hydrocarbon
Monitoring
Location
for
Short
Cement
Kilns
Burning
Hazardous
Waste
at
Other
Locations
Than
the
"
Hot"
End
of
the
Kiln
A
one­
time
request
to
use
the
alternative
hydrocarbons
and
carbon
monoxide
monitoring
provisions
must
be
included
in
the
performance
test
workplan.
EPA
estimates
that
3
cement
kilns
will
choose
to
make
this
request.
Each
request
is
estimated
to
take
1.5
hours
to
prepare.

3.
Deletion
of
Baghouse
Inspection
Requirements
The
requirement
that
sources
identify
and
comply
with
baghouse
inspection
and
monitoring
requirements
on
a
site­
specific
basis
rather
than
comply
with
the
generic,
comprehensive
requirements
in
the
final
rule
will
reduce
recordkeeping
and
reporting
activities
somewhat.
For
example,
a
source
could
conclude
that
less
frequent
inspections,
or
alternative
monitoring
activities,
will
be
more
appropriate,
and
less
burdensome,
for
its
facility.
Moreover,
however,
baghouse
inspection
and
monitoring
activities
must
be
specified
in
the
source's
operation
and
maintenance
plan
irrespective
of
whether
those
activities
are
developed
on
a
site­
specific
basis
or
the
prescribed
activities
in
the
final
rule.

4.
Feedstream
Analysis
for
Organic
HAPs
The
direct
final
rule
will
reduce
the
feedstream
organic
characterization
requirements
by
not
requiring
analysis
of
non­
hazardous
waste
feedstreams
and
by
allowing
sources
to
conduct
less
comprehensive
analysis
of
organic
compounds.
This
reduced
analytical
burden
also
reduces
13
recordkeeping
and
reporting
activities
somewhat.

6(
e)
Bottom
Line
Burden
Hour
and
Cost
Tables
Exhibit
1
shows
that
the
recordkeeping
and
reporting
requirements
of
the
four
withdrawn
amendments
decrease
the
burden
to
the
regulated
community
by
2
hours
per
year
at
a
total
labor
cost
of
$
83
per
year.
This
recordkeeping
and
reporting
burden
reduction
is
incremental
to
the
burden
approved
under
EPA
ICR
Request
#
1773.03.

In
addition,
Exhibit
2
shows
that
the
withdrawn
amendments
will
save
EPA
an
additional
124
hours
per
year
to
review
and
respond
to
the
required
submissions
at
a
cost
savings
of
$
3,447
per
year.

6(
f)
Reasons
for
Change
in
Burden
This
ICR
shows
the
estimated
incremental
burden
reduction
resulting
from
withdrawal
of
the
four
direct
final
amendments
that
received
adverse
public
comment
(
EPA
ICR
Request
#
1773.03).

6(
g)
Burden
Statement
The
average
respondent
reporting
and
recordkeeping
burden
under
this
ICR
is
estimated
to
be
less
than
1
hour/
year
per
facility.
Each
burden
component
is
estimated
to
be
as
follows:


The
average
respondent
reporting
burden
under
this
ICR
is
estimated
to
be
about
0
(
zero)
hours
per
year
per
facility.


The
average
respondent
recordkeeping
burden
is
estimated
to
be
about
0
(
zero)
hours
per
year
per
facility.

Burden
means
that
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
purpose
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
inclose
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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
the
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave,
N.
W.,
Washington,
DC,
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
