SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units 

Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units 

Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal), EPA 

ICR Number 1901.06, OMB Control Number 2060-0424. 

1(b) Short Characterization/Abstract

The Emission Guidelines and Compliance Times for Small Municipal Waste Combustion 

Units Constructed on or Before August 30, 1999 were originally promulgated in December 1995, 

but were vacated by the Federal Court in March 1997. Subsequently, the Emission Guidelines 

were re-proposed on August 30, 1999, and promulgated on December 6, 2000 (65 FR76378). 

The Emission Guidelines regulate organics (dioxin/furans), metals (cadmium, lead, mercury), 

particulate matter, and acid gases (hydrogen chloride, sulfur dioxide, and nitrogen oxides) for 

small Municipal Waste Combustion (MWC) units. Small MWC units are MWC units with 

capacities to combust greater than 35 tons per day (tpd) and less than 250 tons per day (tpd) of 

municipal solid waste. The Emission Guidelines contain monitoring, reporting, and 

recordkeeping requirements that are to be included in state plans. This Information Collection 

Request (ICR) identifies the burden for States and U.S. territories to develop and implement 

State plans, and the burden for small MWCs imposed by these State plans. This information is 

being collected to assure compliance with 40 CFR Part 60, Subpart BBBB. 

In general, all Emission Guidelines require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. 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 Emission Guidelines.

Any owner/operator 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 United 

States Environmental Protection Agency (EPA) regional office.

The “Affected Public” is owners and operators of existing small MWC units. The burden 

to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost –

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units 

Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal). The 
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“Federal Government” burden is attributed entirely to work performed by federal employees or 

government contractors and may be found in Table 2: Average Annual EPA Burden and Cost –

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units 

Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).

Based on our consultations with industry representatives, there are an average of 2.3

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, approximately 54 facilities located at 23 plants (23

respondents) per year will be subject to the Emission Guidelines. Of the 23 respondents, 19 are 

privately-owned, and 4 are owned by state, or local, or tribal governments. Since the Emission 

Guidelines only apply to sources that commenced construction on or before August 30, 1999, no 

additional MWC units will become subject to the standard over the next three years.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance”.

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 
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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;
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(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; . . ..

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 also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test 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 check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard 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. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart

BBBB.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted its 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 
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Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, 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 the EPA 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.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both the Solid Waste Association of North America (SWANA), at (240) 

494-2253; the National Solid Waste Management Association (NSWMA), at (202) 364-3773; 

Veolia ES Solid Waste at (414) 479-7883; and Covanta, at (973) 882-7253.

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. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

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 
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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 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 (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 small MWC units 

constructed on or before August 30, 1999. The United States Standard Industrial Classification 

(SIC) codes for the respondents affected by the standards, and the corresponding North 

American Industry Classification System (NAICS) codes are listed in the table below.

Standard (40 CFR Part 60, Subpart BBBB) SIC Codes NAICS Codes

Air and Water Resource and Solid Waste 

Management 9511 92411

Refuse System; Solid Waste Combustors and 

Incinerators 4953 562213

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the Emission 

Guidelines and Compliance Times for Small Municipal Waste Combustion Units Constructed on 

or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB).
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State/US protectorates must perform the following requirements:

Requirement

Submit a state plan 60.1505

Submit a negative declaration 60.1510

A source must make the following reports:

Notifications

Construction/reconstruction 60.7(a)(1)

Notification of completion of each increment of progress 60.1585

Actual startup 60.7(a)(3)

Performance test and demonstration of continuous monitoring system 60.7(a)(5)

Physical or operational change 60.7(a)(4)

Reports

Initial report 60.8 (a) & (d), 

60.1860, 60.1875

Annual Report 60.1680, 60.1880

Semiannual reports for any emission or parameter that does not meet 

limits

60.1680, 60.1890, 

60.1895, 60.1900

A source must keep the following records:

Recordkeeping

Startups, shutdowns, and malfunctions, periods where the continuous 

monitoring system is inoperative.

60.7(b)

Emission test results and other data needed to determine emissions. 60.1830, 60.1835, 

60.1845

Operator training & certification 60.1830, 60.1835, 

60.1840

Record for MWCs using activated carbon 60.1830, 60.1835, 

60.1855

Records for continuously monitored pollutants or parameters. 60.1830, 60.1850
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Recordkeeping

Records are required to be retained for 5 Years. All five years of 

records must be retained at the facility.

60.1835

Electronic Reporting

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CEMS for SO2, NOx, opacity, CO, CO2 & O2.

Perform initial performance test and reports (PM, dioxin/furans, opacity, fugitives, HCL, Cd, 

Pb, Hg), 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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities
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EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS. 

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 operated. 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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS 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/operator for five

years.

5(c) Small Entity Flexibility

Some of the small MWC units potentially affected by the Emission Guidelines are owned 

by small businesses, non-profit organizations or governments. The EPA does not expect the 

standards to adversely affect these small entities. The standards only apply to units with 

capacities between 35 tpd and 250 tpd. Furthermore, the standards contain provisions for reduced 

testing. Owners of small MWC units where the aggregate plant capacity is less than 250 tpd can 

skip annual tests for 2-year periods for certain pollutants if they have demonstrated compliance 

for three annual tests in a row. In addition to this 3-year testing option, less frequent dioxin/furan 

testing is possible if all units at a plant achieve emission levels less than the emission limit for 

two consecutive years. This provision allows plants to test only one unit per year, rather than all 
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units, as normally required.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – Emission Guidelines and 

Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before 

August 30, 1999 (40 CFR Part 60, Subpart BBBB) (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. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 102,000 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the Emission Guidelines program, the 

previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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
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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)

Load monitors, 

temperature monitors, 

and carbon federate 

monitors (Sections 

60.1315 thru 60.1335)

$200,000 0 $0 $19,200 54 $1,036,800

TOTAL $1,040,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $1,040,000. 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 $1,040,000.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$125,000.

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)
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These rates are from the Office of Personnel Management (OPM), 2015 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 

and Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before 

August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).

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

There are 55 States and U.S. territories subject to the Emission Guidelines. These are the 

air quality programs in 50 States, one federal district, and four U.S. territories.

In addition, the regulations developed under the emissions guidelines apply to small 

MWC’s. Based on our research for this ICR, on average over the next three years, 

approximately 23 existing respondents (19 privately-owned, and 4 state, or local, or tribal 

governments) will be subject to the standard. It is estimated that no additional respondents per 

year will become subject. The overall average number of respondents, as shown in the table 

below, is 23 per year.

The number of respondents is calculated using the following tables that address the three 

years covered by this ICR.

Number of State and U.S. Protectorate

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 55 0 0 55

2 0 55 0 0 55

3 0 55 0 0 55

Average 0 55 0 0 55

Note: The respondents include the 50 States, one federal district (Washington D.C.), and four territories (America 

Samoa, Puerto Rico, Virgin Islands, and Northern Mariana Islands). See 40 CFR Part 62. 

1 New respondents are those who previously submitted a negative declaration but subsequently identify find a small 

MWC unit. 

Number of Respondents
13

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 23 0 0 23

2 0 23 0 0 23

3 0 23 0 0 23

Average 0 23 0 0 23

1

New respondents include sources with constructed, reconstructed and modified affected facilities.

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 23. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

State plan 0 1 0 0

Negative Declaration 0 1 0 0

Plant Startup (Plant Control Plan, 

notifications, etc.) 0 5 0 0

Notifications (Performance Test, 

CEMS Demonstration, etc.) 0 4 0 0

Annual Reports 23 2.35 0 54.05

Semiannual Excess Emission 

Reports 2.3 2 0 4.6

Total 59 (Rounded)

The number of Total Annual Responses is 59 (rounded) (49 for privately-owned MWC 

units and 10 for state, or local, or tribal government MWC units).

The total annual labor costs are $10,200,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines and 

Compliance Times for Small Municipal Waste Combustion Units Constructed on or Before 

August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).
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6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 102,000. Of this burden, 84,300 hours are attributed to 

sources owned by the private sector, and 17,700 hours are attributed to sources owned by state 

and local government. Details regarding these estimates may be found in Table 1: Annual 

Respondent Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal 

Waste Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart 

BBBB) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 1,729 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,040,000.

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

Category No. of 

Respondents

Reporting 

Hours

Recordkeeping 

Hours

Total Labor 

Hours

Respondent 

Labor Cost

Capital & 

O&M Cost

No. of 

Responses

Private 19 75,600 8,700 84,300 $8,430,000 $859,000 49

State & Local 

Government 4 15,900 1,800 17,700 $1,770,000 $181,000 10

Total 23 91,500 10,500 102,000 $10,200,000 $1,040,000 59

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

2,750 labor hours at a cost of $125,000. See Table 2: Average Annual EPA Burden and Cost –

Emission Guidelines and Compliance Times for Small Municipal Waste Combustion Units 

Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 
15

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent burden from the most recently

approved ICR. The increase in respondent labor hour is caused by a change in assumption; in 

this ICR, we assume all existing sources will take some time each year to re-familiarize 

themselves with the rule requirements. There is also a small increase in the total O&M cost due 

to rounding of all calculated values to three significant digits. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 1,729 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2012-0517. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, 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 docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 
16

Number EPA-HQ-OECA-2012-0517 and OMB Control Number 2060-0424 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
17

Table 1: Annual Respondent Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal Waste 

Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal)

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(D) 

Respondents 

per yeara

(E)

Technical 

personhours per 

year

(F)

Management 

personhours per 

year

(G) 

Clerical 

person 

hours 

per 

year

(H) Cost b $

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read and Understand Rule Requirements 40 1 40 23 920 46 92 $106,394.27 

 B. Required Activities

 i. Initial performance tests and reports (PM, 

dioxins/furans, opacity, fugitives, HCl, Cd, Pb, 

Hg) 775 1 775 0 0 0 0 $0 

 ii. CEMS demonstration (SO2, NOx, opacity, 

CO, CO2, O2)

 a. Installation of CEM units 225 1 225 0 0 0 0 $0 

 b. Initial demonstration 450 1 450 0 0 0 0 $0 

 iii. Annual performance tests and test reports 

(PM, dioxins/furans, opacity, fugitives, HCl, Cd, 

Pb, Hg) 775 1 775 23 17,825.00 891.25 1782.5 $2,061,389.06 

 iv. Quarterly Appendix F audits of CEMS 

(SO2, NOx, CO)

 a. RATA audit (one per year) 350 2.3 805 23 18,515.00 925.75 1,851.5 $2,141,184.76 

 b. RAA audit (three per year) 130 6.9 897 23 20,631.00 1,031.55 2,063.1 $2,385,891.59 

 c. Daily calibration and operation 1 840 840 23 19,320.00 966 1932 $2,234,279.75 

 C. Create Information See 3B

 D. Gather Information See 3E

 E. Report Preparation

 i. Plant startup
18

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(D) 

Respondents 

per yeara

(E)

Technical 

personhours per 

year

(F)

Management 

personhours per 

year

(G) 

Clerical 

person 

hours 

per 

year

(H) Cost b $

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

 a. Plant Control Plan 40 1 40 0 0 0 0 $0 

 b. Notification of Contract Awards 4 1 4 0 0 0 0 $0 

 c. Notification of on-site construction start 4 1 4 0 0 0 0 $0 

 d. Notification of construction completion 4 1 4 0 0 0 0 $0 

 e. Notification of final completion 4 1 4 0 0 0 0 $0 

 ii. Notification of initial performance tests 4 1 4 0 0 0 0 $0 

 iii. Initial compliance reports 40 1 40 0 0 0 0 $0 

 iv. Notification of CEMS demonstration 4 1 4 0 0 0 0 $0 

 v. Initial CEMS demonstration report 90 1 90 0 0 0 0 $0 

 vi. Annual compliance reports 40 2.3 92 23 2,116 105.8 211.6 $244,706.83 

 vii. Semiannual excess emission reports 40 2 80 2.3 184 9.2 18.4 $21,278.85 

Reporting Subtotal 91,438 $9,195,125.13 

4. Recordkeeping Requirements

 A. Read and Understand Rule Requirements See 3A

 B. Plan Activities See 3B

 C. Implement Activities See 3B

 D. Develop Record System N/A

 E. Record information

 i. Record startups, shutdowns, and 

malfunctions h4 47 188 23 4,324 216.2 432.4 $500,053.09 

 ii. Records of all emission rates, 

computations, tests 4 47 188 23 4,324 216.2 432.4 $500,053.09 

 iii. Records of employee review of operations 

manual 4 1 4 23 92 4.6 9.2 $10,639.43 
19

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours per 

respondent 

per year

(D) 

Respondents 

per yeara

(E)

Technical 

personhours per 

year

(F)

Management 

personhours per 

year

(G) 

Clerical 

person 

hours 

per 

year

(H) Cost b $

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

 iv. Record amount of sorbent used for Hg and 

dioxin/furan control 4 4 16 23 368 18.4 36.8 $42,557.71 

 F. Personnel Training N/A

 G. Time for audits N/A

Recordkeeping subtotal 10,474 $1,053,303.31 

TOTAL LABOR BURDEN AND COST 

(Rounded):i102,000 $10,200,000 

Capital and O&M Cost (see Section 6(b)(iii)): i

$1,040,000 

TOTAL COST: i

$11,200,000 

Assumptions:

a Assumes an average of 2.3 affected facilities (i.e., sources or units) per respondent [53 facilities at 23 plants; 53/23 = 2.3 (Rounded)].

b No additional facilities will become subject to the standard over the next three years.

c This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, 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.

d Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 2.3 = 2.3). RATA are performed for one of the four quarterly audits.

RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO 

monitors will incorporate the use of the diluent monitor.

e Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 2.3 = 6.9).

f Daily calibration and operation data occurs daily [365 x 2.3 = 840 (Rounded)].

g Assumes 10 percent of sources (2.3) have affected facilities with excess emissions and must submit two semiannual reports.

h Assumes 47 weeks of operation (90 percent availability) per year per facility.

i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
20

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines and Compliance Times for Small Municipal Waste 

Combustion Units Constructed on or Before August 30, 1999 (40 CFR Part 60, Subpart BBBB) (Renewal)

Activity

(A)

Number of

occurrence

per year

(B)

EPA personhours per 

occurrence

(C)

Technical 

person-hours 

per year

(D)

Management 

person-hours per 

year

(E)

Clerical 

personhours per 

year

(H)

Costa$

(C=AxB) (Ex0.05) (Ex0.1)

1. Prepare and submit State plan and negative 

declarationb N/A

2. Report Reviews

i. Review preliminary and final 

material separation plans and siting analysis b0 8 0 0 0 $0

ii. Review notification of construction b0 2 0 0 0 $0

iii. Review notification of startup b0 2 0 0 0 $0

iv. Review notification of initial performance 

 test b0 8 0 0 0 $0

v. Review notification of initial CEMS 

 demonstration b0 4 0 0 0 $0

vi. Review initial performance test report b0 40 0 0 0 $0

vii. Review initial CEMS demonstration report b0 40 0 0 0 $0

viii. Review annual compliance report c, d 23 92 2,116 105.8 211.6 $110,754.83

ix. Review semi-annual excess emission report e4.6 16 73.6 3.68 7.36 $3,852.34

3. Prepare annual summary report 1 200 200 10 20 $10,468.32

TOTAL ANNUAL COST (rounded)f

2,750 $125,000
21

Assumptions:

a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90

Managerial rate (GS-13, Step 5, $39.31 x 1.6), $46.67 Technical rate (GS-12, Step 1, $29.17 x 1.6), and $25.25 Clerical rate (GS-6, Step 3, $15.78 x 1.6).

These rates are from the Office of Personnel Management (OPM) 2015 General Schedule, which excludes locality rates of pay.

b No additional sources will become subject to the standard over the next three years. We also assume affected air quality program administrator in States and 

U.S. territories have already submitted a State Plan and/or negative declaration.

c Assumes 54 affected units at 23 plants.

d Assumes four hours to review the annual compliance report for each plant (4 x 23 = 92).

e Assumes submission of semiannual excess emission reports will be required for 10 percent of units (2.3); (2 x 2.3 = 4.6).

f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.