Supporting
Statement
for
EPA
Information
Collection
Request
#
1773.07
(
OMB
Control
#
2050­
0171)

Reporting
and
Recordkeeping
Requirements
for
NESHAP:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors
(
Final
Amendments
Rule);
Final
Rule
February
2002
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Characterization
of
the
Information
Collection
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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1
2(
a)
Need
and
Authority
for
the
Collection
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.
1
2(
b)
Use
and
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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2
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
and
NAICS
Codes
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3
4(
b)
Information
Collected
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4
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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9
5(
a)
Agency
Activities
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9
5(
b)
Collection
Methodology
and
Management
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9
5(
c)
Small
Entity
Flexibility
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10
5(
d)
Collection
Schedule
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10
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
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10
6(
a)
Estimating
Respondent
Burden
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10
6(
b)
Estimating
Respondent
Cost
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10
6(
c)
Estimating
Agency
and
State
Burden
and
Cost
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11
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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11
6(
e)
Bottom
Line
Burden
Hour
and
Cost
Tables
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14
6(
f)
Reasons
for
Change
in
Burden
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14
6(
g)
Burden
Statement
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14
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Reporting
and
Recordkeeping
Requirements
for
NESHAP:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors
(
Final
Amendments
Rule);
Final
Rule,"
EPA
ICR
#
1773.07
(
OMB
Control
#
2050­
0171).

1(
b)
Characterization
of
the
Information
Collection
This
ICR
describes
the
incremental
recordkeeping
and
reporting
burden
to
an
existing
rule
that
EPA
is
amending.
We
promulgated
new
emission
standards
and
controls
for
hazardous
waste
combustors
 
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
 
on
September
30,
1999
(
64
FR
52828).
On
July
3,
2001,
we
published
a
direct
final
rule
(
66
FR
35087)
and
a
notice
of
proposed
rulemaking
(
66
FR
35126)
that
promulgated
and
proposed
a
number
of
amendments
to
the
September
30,
1999
final
rule.
We
published
thirteen
of
those
amendments
as
direct
final
rules
because
we
believed
the
amendments
to
be
non­
controversial.
However,
we
further
stated
that
if
we
received
adverse
comment
on
one
or
more
of
the
amendments,
we
would
publish
in
the
Federal
Register
a
timely
withdrawal
of
the
amendments
that
received
adverse
comment,
and
deal
with
those
amendments
as
proposed
rules.
We
subsequently
received
adverse
comment
on
four
of
the
thirteen
amendments,
and
we
withdrew
the
four
amendments
on
October
15,
2001
(
66
FR
52361).
The
scope
of
this
ICR
includes
the
four
amendments
that
received
adverse
comment
and
a
subset
of
the
twenty
amendments
also
proposed
on
July
3,
2001.
The
initial
paperwork
burden
for
the
September
30,
1999
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."
[
Note:
EPA
also
promulgated
recently
a
final
rule
that
had
an
EPA
ICR
Request
#
1773.06
assigned
to
it.
The
burden
estimates
in
this
ICR
are
incremental
from
totals
in
#
1773.06.]

This
ICR
estimates
the
additional
(
incremental)
recordkeeping
and
reporting
burdens
as
a
result
of
the
Amendments:


The
recordkeeping
and
reporting
requirements
result
in
an
estimated
increased
burden
to
the
regulated
community
of
1,294
hours
per
year
at
a
total
labor
cost
of
$
75,642
per
year.
This
recordkeeping
and
reporting
burden
would
be
incremental
to
the
burden
approved
under
EPA
ICR
Request
#
1773.02
(
and
later
modified
by
EPA
ICR
Requests
#
1773.03,
#
1773.05,
and
#
1773.06).


In
addition,
it
would
take
EPA
an
additional
1,082
hours
per
year
to
review
and
respond
to
the
required
submissions
at
an
additional
cost
of
$
29,383
per
year.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
September
30,
1999
final
rule
established
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
under
authority
of
section
112
of
the
Clean
Air
Act
for
three
source
categories:
Hazardous
waste
burning
incinerators,
hazardous
waste
burning
cement
kilns,
and
hazardous
waste
burning
lightweight
aggregate
kilns.
The
main
purpose
of
the
Clean
Air
Act
is
to
protect
and
enhance
the
quality
of
our
Nation's
air
resources,
and
to
promote
the
2
public
health
and
welfare
and
the
productive
capacity
of
the
population.
See
Clean
Air
Act
section
101(
b)(
1).
To
this
end,
sections
112(
a)
and
(
d)
of
the
Clean
Air
Act
direct
EPA
to
set
standards
for
stationary
sources
emitting
(
or
having
the
potential
to
emit)
ten
tons
or
greater
of
any
one
hazardous
air
pollutant
or
25
tons
or
greater
of
total
hazardous
air
pollutants
annually.
The
records
and
reports
required
by
this
information
collection
are
used
to
show
or
to
request
alternative
means
to
comply
with
requirements
of
the
rule.

2(
b)
Use
and
Users
of
the
Data
The
data
collected
for
hazardous
waste
combuster
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
the
rule's
requirements.
Notifications
and
submitted
monitoring
data
are
used
by
EPA
or
the
implementing
agency
to
evaluate
construction
and
reconstruction
plans,
test
and
operating
plans,
test
results,
facility
operation,
and
whether
facilities
qualify
for
certain
exemptions
and
alternative
monitoring
and
testing
methods.
Some
of
the
information
also
serves
an
opportunity
for
public
participation.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
has
determined
that
no
other
Federal
agency
collection
satisfies
the
statutory
requirements
of
section
112
of
the
Clean
Air
Act,
as
amended.
None
of
this
information
is
duplicative
of
other
information
collected
by
other
EPA
offices
or
other
federal
agencies.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
solicited
public
comment
on
this
ICR
through
an
announcement
in
the
Federal
Register
on
July
3,
2001.
See
66
FR
35087
and
66
FR
35126.
The
public
comment
period
ended
October
16,
2001.
We
did
not
receive
any
comments
on
the
proposed
ICR.

3(
c)
Consultations
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.
We
worked
and
consulted
directly
with
the
impacted
respondent
stakeholders
and
trade
group
associations
when
developing
these
revisions;
and
that
the
specific
requirements
of
the
amendments
consider
comments
from
and
meetings
with
the
impacted
respondent
stakeholders.

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,
we
are
confident
that
those
activities
required
of
respondents
are
necessary,
and
to
the
extent
possible,
minimize
the
burden
imposed.
We
believe
that,
if
the
minimum
requirements
specified
under
the
regulations
are
not
met,
we
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
3
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
Paperwork
Reduction
Act
of
1995,
OMB's
implementing
regulations,
and
OMB's
Information
Collection
Review
Handbook
(
EPA,
April
1998).

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
defines
EPA's
general
policy
on
the
public
disclosure
of
information,
contain
provisions
for
confidentiality.
Some
businesses
consider
some
of
their
hazardous
waste
information
to
be
Confidential
Business
Information
(
CBI).
A
business
may,
if
it
desires,
protect
its
Hazardous
Waste
Report
information
from
public
disclosure
by
asserting
a
claim
of
confidentiality
covering
all
or
part
of
the
information
it
furnishes
to
EPA.
When
such
a
claim
is
asserted,
we
must
and
will
treat
the
information
in
accordance
with
the
confidentiality
regulations.
We
also
ensure
that
the
information
collection
procedures
comply
with
the
Privacy
Act
of
1974
and
the
OMB
Circular
108.

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
and
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
3253
Pesticide
and
Fertilizer
3254
Pharmaceutical
and
Medicine
3255
Paint,
Coating,
and
Adhesive
4
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
1.
Use
of
Previous
DRE
Test
Results
to
Demonstrate
Compliance
with
the
MACT
DRE
Standard
(
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
in
most
cases
the
age
restriction
on
usable
destruction
and
removal
efficiency
(
DRE)
test
data.
The
second
revision
eliminates
the
requirement
that
specifies
that
inlieu
data
must
have
been
collected
for
the
purpose
of
RCRA
permit
issuance
or
re­
issuance.
Instead,
acceptable
data
must
have
been
obtained
with
the
same
level
of
oversight
and
quality
as
those
data
obtained
during
the
RCRA
permitting
process.

(
ii)
Respondent
activity
If
a
source
chooses
to
submit
previous
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
previous
data
are
suitable
for
a
compliance
determination.

2.
Hydrocarbon
Monitoring
Requirements
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
by­
pass
duct
and
at
a
preheater
tower
combustion
gas
monitoring
location
5
(
§
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
If
a
source
chooses
the
alternative
monitoring
scheme
for
hydrocarbons,
their
request
must
be
made
as
an
additional
item
in
the
comprehensive
performance
test
plan.

3.
Deleting
the
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.
This
amendment
is
applicable
only
to
incinerators
and
lightweight
aggregate
kilns.

(
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,
prescriptive
requirements.

4.
Requirements
for
Feedstream
Analysis
of
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.
Revisions
to
Combustion
System
Leak
Provisions
(
i)
Data
items,
including
recordkeeping
requirements
Additions
and
clarifications
to
the
requirement
for
instantaneous
monitoring
of
combustion
zone
pressure
for
controlling
combustion
zone
fugitive
emissions
are
made
to
ensure
intended
flexibility,
including:
(
1)
instantaneous
pressure
monitors
must
detect
and
record
pressure
at
a
frequency
adequate
to
detect
combustion
system
leaks,
determined
on
a
site­
specific
6
basis;
(
2)
the
comprehensive
performance
test
workplan
and
Notification
of
Compliance
must
specify
the
procedures
to
control
combustion
leaks;
and
(
3)
alternative
techniques
other
than
combustor
pressure
monitoring
may
be
used
to
prevent
fugitive
emissions
when
reviewed
and
approved
by
the
Administrator.

(
ii)
Respondent
activity
Sources
must
include
the
most
reasonable
frequency
and
procedure
for
recording
and
monitoring
of
combustion
system
fugitive
emissions
in
the
performance
test
workplan
and
Notification
of
Compliance.

6.
Revisions
to
Operator
Training
and
Certification
Requirements
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
revising
the
certification
requirements:

(
1)
Allow
sources
to
use
site­
specific,
source
developed
and
implemented
training
and
certification
programs
in
lieu
of
the
ASME
program
or
the
State
program.
For
sources
choosing
to
use
a
site­
specific
program,
we
prescribe
specific
training
topics.

(
2)
For
sources
choosing
to
use
the
ASME
program,
we:
(
1)
require
only
provisional
certification
by
the
compliance
date
for
existing
facilities;
(
2)
new
operators
require
provisional
certification
at
the
date
they
assume
duties,
provided
that
they
achieve
full
certification
within
one
year.

(
3)
Deleting
the
requirement
that
shift
supervisors
be
trained
and
certified
under
the
same
program
designed
for
control
room
operators.
We
require
that
shift
supervisors,
like
other
employees,
only
be
trained
and
certified
as
capable
to
perform
their
specific
duties.

(
4)
Control
room
operators
are
required
to
complete
an
annual
review
or
refresher
course
covering
prescribed
topics
to
maintain
certification.

(
5)
A
certified
control
room
operator
must
be
on
duty
at
the
source
at
all
times
the
source
is
in
operation.

(
ii)
Respondent
activity
Most
sources
are
anticipated
to
choose
to
use
a
site­
specific,
source­
developed
and
implemented
training
and
certification
program.
Under
this
approach,
sources
must
develop,
submit
for
approval,
and
implement
the
program
and
keep
records
of
training
and
certification
activities.
If
a
source
chooses
to
use
the
ASME
program,
recordkeeping
and
reporting
activity
would
not
increase
(
compared
to
the
requirements
of
the
September
30,
1999
final
rule).

7.
Time
Extensions
For
Performance
Testing
if
the
Test
Plan
Has
Not
Been
Approved
(
i)
Data
items,
including
recordkeeping
requirements
Sources
will
be
allowed
to
petition
the
Administrator,
under
the
authority
of
§
63.7(
h),
to
obtain
a
"
waiver"
of
any
performance
test,
including
the
initial
or
periodic
performance
test,
7
comprehensive
test,
or
confirmatory
test,
if
the
performance
test
plan
is
not
approved.
The
source
can
also
request
a
second
6
month
waiver
if
the
plan
is
not
approved
following
the
initial
6
month
period.

Sources
must
submit
the
waiver
petition
or
request
to
renew
the
petition
to
the
Administrator.
A
separate
petition
must
be
submitted
for
each
source
at
least
60
days
prior
to
the
scheduled
date
of
the
performance
test.
It
must
include
documentation
to
enable
the
Administrator
to
determine
that
the
source
is
meeting
the
relevant
standard(
s)
on
a
continuous
basis
as
required
by
§
63.7(
h)(
2).
Extension
requests
for
the
initial
comprehensive
performance
test
must
include
a
Documentation
of
Compliance
to
assist
the
Administrator
in
making
this
determination.
The
petition
also
must
include
information
justifying
the
request
for
a
waiver,
such
as
the
technical
or
economic
impracticality
of
the
affected
source
performing
the
required
test,
as
required
by
§
63.7(
h)(
3)(
iii).
Finally,
the
source
must
notify
the
public
of
the
petition
to
waive
a
performance
test.

(
ii)
Respondent
activity
Sources
may
choose
to
request
a
time
extension
to
conduct
performance
testing
if
the
test
plan
has
not
been
approved.
If
so,
they
must
prepare
and
submit
a
request
for
a
testing
extension
waiver
and
notify
the
public
about
the
request.

8.
Flexibility
in
Operations
During
Confirmatory
Performance
Testing
for
Dioxin/
Furans
(
i)
Data
items,
including
recordkeeping
requirements
EPA
is
making
revisions
to
allow
sources
to
petition
to
operate
under
a
wider
operating
range
based
on
information
justifying
that
operating
within
the
required
range
may
be
problematic.
Also,
Administrator
can
accept
test
results
based
on
operations
outside
of
the
range
specified
in
the
confirmatory
test
plan.

(
ii)
Respondent
activity
A
source
may
choose
to
request
in
the
test
plan
to
operate
under
a
wider
range
during
their
test
if
they
justify
that
operating
within
the
required
range
may
be
problematic.

9.
Waiving
Operating
Parameter
Limits
during
Performance
Testing
and
Pretesting
EPA
is
deleting
test
plan
approval
as
a
requirement
prior
to
waiving
operating
parameter
limits
during
performance
testing
or
pretesting.

(
i)
Data
items,
including
recordkeeping
requirements
None.

(
ii)
Respondent
activity
None.

10.
Calibration
Requirements
for
Temperature
Measurement
Devices
(
i)
Data
items,
including
recordkeeping
requirements
8
EPA
is
revising
the
temperature
measurement
device
calibration
procedure
and
frequency
to
be
included
as
part
of
the
evaluation
test
plan
that
is
required
by
§
63.8(
e)(
3)(
i)
and
applies
to
all
continuous
monitors;
and
that
the
frequency
be
consistent
with
manufacturer
recommendations
but
not
to
exceed
at
least
once
per
year.

(
ii)
Respondent
activity
The
continuous
monitoring
system
evaluation
plan
and
test
plan
would
continue
to
include
calibration
procedure
and
frequency
for
all
measurement
and
monitoring
devices.
The
recordkeeping
activities
for
calibration
of
temperature
measurement
devices
are
reduced
with
the
less
frequent
calibration.

11.
Revisions
to
Particulate
Matter
Operating
Requirements
for
Activated
Carbon
Injection
and
Carbon
Bed
Systems
(
i)
Data
items,
including
recordkeeping
requirements
In
lieu
of
a
site­
specific
particulate
matter
limit,
§
63.1209(
k)(
5)
is
being
revised
for
units
using
activated
carbon
injection
to
require
operating
limits
on
particulate
matter
control
devices
consistent
with
the
approach
used
to
control
particulate
matter
for
semivolatile
metals
and
low
volatile
metals
control.
Also,
for
sources
equipped
with
carbon
beds
EPA
is
deleting
the
requirement
to
establish
particulate
matter
operating
parameters
to
ensure
compliance
with
the
dioxin/
furan
and
mercury
emission
standards.

These
revisions
do
not
change
recordkeeping
and
reporting
activities
because:
(
1)
sources
equipped
with
carbon
injection
systems
must
still
establish
limits
on
operating
parameters
to
control
particulate
matter
based
on
the
performance
test;
and
(
2)
there
are
no
operating
parameters
for
particulate
matter
control
for
carbon
bed
systems
and
this
revision
serves
as
a
clarification.

(
ii)
Respondent
activity
The
rationale
for
the
selection
of
all
operating
parameter
limits
must
be
contained
in
the
performance
test
workplan.
All
operating
parameters
tied
to
automatic
waste
feed
cutoffs
must
be
monitoring
and
recorded
as
required
in
the
September
30,
1999
final
rule.

12.
How
to
Comply
Temporarily
with
Alternative,
Otherwise
Applicable
MACT
Standards
In
lieu
of
the
HWC
MACT
standards,
EPA
clarifies
how
sources
may
comply
temporarily
with
otherwise
applicable
MACT
standards
after
the
hazardous
waste
residence
time
has
expired.
Three
options
for
calculating
rolling
averages
immediately
after
operating
mode
change
are
provided.

(
i)
Data
items,
including
recordkeeping
requirements
No
new
requirements.

(
ii)
Respondent
activity
No
new
requirements.

13.
Less
Sensitive
Bag
Leak
Detection
System
9
(
i)
Data
items,
including
recordkeeping
requirements
Section
63.1206(
c)(
7)(
ii)
of
the
September
30,
1999
final
rule
prescribes
baghouse
operation
and
maintenance
requirements
for
incinerators
and
lightweight
aggregate
kilns,
including
a
requirement
for
the
continuous
operation
of
a
bag
leak
detection
system
as
a
continuous
monitor.
This
amendment
allows
a
source
to
petition
the
Administrator
to
use
a
bag
leak
detector
that
has
a
detection
limit
greater
than
1
mg/
acm.

(
ii)
Respondent
activity
If
a
source
wants
to
use
a
less
sensitive
bag
leak
detector,
they
must
submit
a
petition
to
the
Agency
using
the
alternative
monitoring
provisions
under
§
63.1209(
g)(
1).

14.
Technical
Corrections
(
i)
Data
items,
including
recordkeeping
requirements
Several
technical
corrections
are
made,
including
corrections
of
typographical
and
citation
errors
and
corrections
to
40
CFR
part
63,
Subpart
EEE,
and
sections
266.100(
d)
and
270.42(
j)(
1).

(
ii)
Respondent
activity
There
are
no
recordkeeping
or
reporting
activities
related
to
these
minor
technical
corrections.

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
either
reduce
the
burden
or
offer
additional
compliance
flexibility
compared
to
the
September
30,
1999
final
rule.
In
many
cases,
these
requests
are
included
in
the
comprehensive
performance
test
plan,
continuous
monitoring
system
evaluation
plan
and
test
plan,
or
the
operating
and
maintenance
plan.
All
of
these
documents,
including
the
requests,
will
be
reviewed
and
approved
as
necessary
by
EPA.
As
a
result,
EPA
time
to
review
and
approve
these
documents
is
slightly
increased
as
a
result
of
this
rule.
Section
6(
c)
below
shows
the
estimates
of
increased
EPA
and
implementing
agency
burden
for
the
various
amendments.

5(
b)
Collection
Methodology
and
Management
Much
of
the
ICR
activity
is
comprised
of
reporting
requirements
that
are
typically
submitted
by
mail
directly
to
EPA
for
review.
Some
recordkeeping
information,
however,
would
also
be
kept
in
facility
files.
This
requires
the
implementing
authority
to
visit
and
collect
from
the
10
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
Six
out
of
171
combustion
facilities
have
been
categorized
as
small
entities.
EPA
conducted
an
incremental
assessment
of
any
cost
savings
or
cost
burdens
that
may
result
from
the
proposed
amendments
to
the
final
rule
on
these
small
entities.
Based
on
our
analysis
of
available
data,
we
conclude
that
there
would
not
be
a
significant
economic
impact
to
any
of
the
potentially
impacted
small
business
combustor
companies
resulting
from
this
final
rule.
For
details
of
the
analysis,
see
Assessment
of
Potential
Costs,
Benefits
and
Other
Impacts,
and
Regulatory
Flexibility
Screening
Analysis
(
RFSA)
For
NESHAP:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors;
Amendments
to
the
NESHAP:
Final
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Combustors:
Final
Rule,
September
30,
1999,
dated
January
2,
2002,
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
periodic,
but
well
defined,
manner
prior
to
compliance
testing
and
facility
operations.

Although
the
means
by
which
respondents
submit
the
information
is
not
specified,
EPA
anticipates
information
will
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
EPA
presents
estimates
for
the
respondent
burden
hours
associated
with
all
of
the
information
collection
requirements
covered
in
this
ICR
in
Exhibit
1.
The
exhibit
lists
all
of
the
respondent
activities
associated
with
this
final
rule
and
presents
burden
and
cost
estimates
for
each.
The
burden
estimates
are
broken
down
by
labor
category
(
legal,
managerial,
technical,
and
clerical)
and
totaled
on
a
per
activity
basis.
These
burden
estimates
are
then
multiplied
by
the
estimated
number
of
respondents
and
the
estimated
number
of
activities
per
respondent
to
obtain
an
estimate
of
the
overall
burden
to
the
regulated
universe
for
each
activity.

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
three
year
period
of
this
ICR.
Cost
estimate
assumptions
are
discussed
in
the
following
four
subsections.
11
(
i)
Estimating
Labor
Costs
The
average
hourly
labor
cost
for
respondents
is
estimated
at
$
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.
Using
the
total
burden
hours
discussed
in
Section
6(
a)
and
the
wage
rates
outlined
in
this
section,
Exhibit
1
illustrates
the
labor
costs
associated
with
all
of
the
information
collection
requirements
covered
in
this
ICR.

(
ii)
Estimating
Operating
and
Maintenance
Costs
To
submit
information,
notices,
or
requests
to
the
approving
or
permitting
agency,
EPA
estimates
that
facilities
will
incur
a
one­
time
postage
cost
of
$
10.00
per
package
via
registered
mail.
EPA
also
estimates
that
facilities
will
incur
annual
operation
and
maintenance
(
O&
M)
costs
associated
with
maintaining
a
copy
of
their
information
submissions.
EPA
assumes
that
most
facilities
will
submit
their
information
on
paper
and
will
need
to
make
photocopies
and
maintain
copies.
EPA
estimates
that
maintenance
and
photocopying
expenses
will
be
$
0.04
per
page.

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

(
iv)
Annualized
Capital
/
Start­
Up
Costs
There
are
no
capital
/
start­
up
costs
associated
with
this
ICR.

6(
c)
Estimating
Agency
and
State
Burden
and
Cost
EPA
estimates
annual
Agency
burden
hours
and
costs
associated
with
all
requirements
covered
by
this
ICR
in
Exhibit
2.
EPA
believes
that
the
Headquarters,
Regional,
and
State
offices
will
be
involved
in
these
activities.
Burden
is
due
to
increased
hours
to
review
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
may
vary,
depending
on
the
number,
capacity,
and
complexity
of
the
combustion
units
at
the
facility.

(
i)
Universe
Determination
It
is
estimated
that
171
facilities
with
hazardous
waste
combustion
units
are
impacted
by
the
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
0.
Familiarize
With
Rule
EPA
estimates
that
all
171
facilities
with
hazardous
waste
combustion
units
will
read
the
final
rule.
12
1.
Use
of
Previous
DRE
Test
Results
to
Demonstrate
Compliance
with
the
MACT
DRE
Standard
This
amendment
deletes
the
age
requirement
for
previous
in
lieu
data
and
will
potentially
reduce
the
need
for
new
testing
for
compliance
with
the
interim
regulations.
We
note,
however,
that
the
recordkeeping
and
reporting
burden
associated
with
this
amendment
will
not
be
reduced
significantly
(
compared
with
the
September
1999
final
rule
burden
baseline)
because
the
ICR
for
the
September
1999
final
rule
assumed
that
previous
destruction
and
removal
efficiency
(
DRE)
data
will
be
allowable
for
demonstration
of
compliance
with
the
DRE
standard
for
most
all
facilities.

2.
Hydrocarbon
Monitoring
Requirements
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
comprehensive
performance
test
workplan.
It
is
estimated
that
three
cement
kilns
will
choose
to
make
this
request.
Each
request
is
estimated
to
take
1.5
hours
to
prepare.

3.
Deleting
the
Baghouse
Inspection
Requirements
The
amendment
requires
sources
to
identify
and
comply
with
baghouse
inspection
and
monitoring
requirements
on
a
site­
specific
basis
rather
than
comply
with
the
generic,
comprehensive
requirements.
EPA
estimates
that
this
amendment
may
reduce
slightly
the
recordkeeping
and
reporting
activities.
For
example,
a
source
may
conclude
that
less
frequent
inspections,
or
alternative
monitoring
activities,
are
more
appropriate,
and
less
burdensome,
for
its
facility.
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
sitespecific
basis
or
the
prescribed
activities
in
the
final
rule.
Thus,
EPA
anticipates
little
change
in
recordkeeping
and
reporting
burden.

4.
Requirements
for
Feedstream
Analysis
of
Organic
HAPs
EPA
estimates
that
feedstream
organic
characterization
requirements
may
be
reduced
for
approximately
25%
of
the
sources
because
the
amendment
allows
sources
to
conduct
less
comprehensive
analysis
of
organic
compounds
if
the
compounds
used
to
demonstrate
compliance
with
the
destruction
and
removal
efficiency
continue
to
be
representative
of
the
most
difficult
to
destroy
organic
compounds
in
the
hazardous
waste
feedstream.
EPA
anticipates
that
this
amendment
will
reduce
the
analytical
burden
and
recordkeeping
activities
somewhat.
This
amendment
may
also
result
in
a
small
increase
in
reporting
requirements
because
the
requests
must
be
made
in
the
comprehensive
performance
test
plan
and
waste
analysis
plan.
However,
EPA
expects
the
increases
in
the
reporting
requirements
will
be
offset
by
corresponding
reductions
in
subsequent
testing
and
analysis
requirements.

5.
Revisions
to
Combustion
System
Leak
Provisions
There
are
no
additional
recordkeeping
or
reporting
burdens
associated
with
the
revisions
to
the
procedures
for
controlling
combustion
system
leaks
as
compared
to
the
September
30,
1999
final
rule.
The
requirement
to
specify
the
method
a
source
plans
to
use
to
control
combustion
system
leaks
in
the
performance
test
workplan
and
Notification
of
Compliance
remains
the
same.
13
6.
Revisions
to
Operator
Training
and
Certification
Requirements
EPA
estimates
that
50%
of
the
incinerator
sources
may
request
to
develop
a
site­
specific
operator
training
and
certification
program.
The
primary
additional
burden
beyond
that
currently
required,
which
is
to
use
the
American
Society
of
Mechanical
Engineers
(
ASME)
program,
is
the
actual
development
of
the
site­
specific
program.
EPA
estimates
that
the
site­
specific
program
will
likely
be
developed
as
a
modified
ASME
program,
and
we
estimate
that
it
will
take
approximately
40
hours
to
create
initially.
In
addition,
recordkeeping
burden
is
estimated
to
be
3
hours
per
source.

7.
Time
Extensions
For
Performance
Testing
if
the
Test
Plan
Has
Not
Been
Approved
EPA
estimates
that
25%
of
all
facilities
will
choose
to
submit
a
petition
to
the
Administrator
for
extension
of
the
testing
date.
Each
petition
will
require
an
estimated
4
hours
additional
reporting
burden.

8.
Flexibility
in
Operations
During
Confirmatory
Performance
Testing
for
Dioxin/
Furans
This
amendment
allows
a
source
to
operate
under
an
alternative
range
if
the
source
documents
in
the
confirmatory
performance
test
plan
that
it
may
be
problematic
to
maintain
the
required
range
during
the
test.
In
a
related
rulemaking
concurrent
with
this
action,
EPA
is
waiving
confirmatory
testing
for
all
sources
during
the
period
that
the
interim
regulations
are
in
place.
Therefore,
there
are
no
changes
to
the
recordkeeping
or
reporting
burdens
associated
with
these
revisions.

9.
Waiving
Operating
Parameter
Limits
during
Performance
Testing
and
Pretesting
There
are
no
incremental
(
from
the
September
1999
final
rule)
recordkeeping
or
reporting
burdens
associated
with
this
amendment.

10.
Calibration
Requirements
for
Temperature
Measurement
Devices
EPA
estimates
that
the
frequency
of
calibration
of
temperature
measurement
devices
for
all
sources
may
be
reduced,
and,
therefore,
may
decrease
slightly
the
recordkeeping
activity.

11.
Revisions
to
Particulate
Matter
Operating
Requirements
for
Activated
Carbon
Injection
and
Carbon
Bed
Systems
EPA
estimates
that
this
amendment
will
not
result
in
a
change
in
recordkeeping
and
reporting
burden.
Specifically,
deleting
the
requirement
for
sources
using
activated
carbon
injection
systems
to
limit
particulate
matter
emissions
to
levels
achieved
during
the
comprehensive
performance
test
and
instead
requiring
sources
to
establish
operating
limits
on
the
particulate
matter
control
device
results
in
results
in
no
change
because
these
operating
parameter
limits
are
already
required
in
the
September
1999
final
rule.
With
respect
to
deleting
the
requirement
for
sources
equipped
with
carbon
beds
to
establish
particulate
matter
operating
parameter
limits,
we
estimate
that
this
change
will
not
result
in
a
change
in
burden
because
there
are
no
sources
currently
using
particulate
matter
control
devices
downstream
of
a
carbon
bed.

12.
How
to
Comply
Temporarily
with
Alternative,
Otherwise
Applicable
MACT
Standards
There
are
no
incremental
(
from
the
September
1999
final
rule)
recordkeeping
or
reporting
burdens
associated
with
this
amendment.
14
13.
Less
Sensitive
Bag
Leak
Detection
Systems
EPA
estimates
that
75%
of
incinerators
and
50%
of
lightweight
aggregate
kilns
will
petition
for
the
use
of
bag
leak
detectors
with
sensitivities
greater
than
1
mg/
acm.
EPA
also
estimates
that
this
request
will
require
an
additional
0.5
hours
of
effort
per
request
and
will
be
included
in
the
comprehensive
performance
test
plan.

14.
Miscellaneous
Technical
Corrections
There
are
no
recordkeeping
or
reporting
burden
associated
with
the
miscellaneous
technical
corrections.

6(
e)
Bottom
Line
Burden
Hour
and
Cost
Tables
Exhibit
1
shows
the
bottom
line
respondent
burden
and
costs
associated
with
these
amendments
to
the
September
1999
final
rule.
EPA
estimates
that
respondents
will
incur
an
annual
burden
of
1,294
hours
and
a
cost
of
$
75,642
per
year.
This
recordkeeping
and
reporting
burden
would
be
incremental
to
the
burden
approved
under
EPA
ICR
Request
#
1773.02
(
and
later
modified
by
EPA
ICR
Requests
#
1773.03,
#
1773.05,
and
#
1773.06).

Exhibit
2
presents
the
bottom
line
Agency
burden
and
costs
associated
with
these
amendments.
EPA
estimates
an
Agency
annual
burden
of
1,082
hours
and
a
cost
of
$
29,383
per
year.

6(
f)
Reasons
for
Change
in
Burden
This
ICR
shows
the
estimated
incremental
(
from
the
September
1999
final
rule
and
EPA
ICR
Requests
#
1773.02,
#
1773.03,
#
1773.05,
and
#
1773.06)
burden
incurred
by
hazardous
waste
combustors
as
a
result
of
these
amendments.
These
changes
include
new
or
modified,
and
eliminated
in
some
cases,
reporting
and
recordkeeping
requirements.

6(
g)
Burden
Statement
The
average
respondent
reporting
and
recordkeeping
burden
under
this
ICR
is
estimated
to
be
7.6
hours/
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
7.5
hours
per
year
per
facility.


The
average
respondent
recordkeeping
burden
is
estimated
to
be
about
0.1
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.
15
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.
