SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

ICR Number 1506.13, OMB Control Number 2060-0210.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Municipal Waste Combustors were 

proposed on December 20, 1980 and September 20, 1994, respectively, and promulgated on 

February 11, 1991 and December 19, 1995 (respectively). These regulations apply to existing 

and new facilities with a municipal waste combustor unit capacity greater than 225 megagrams 

per day of municipal solid waste. Municipal waste combustor (MWC) facilities that commenced 

construction after December 20, 1989 and on or before September 20, 1994, or commenced 

modification or reconstruction after December 20, 1989 and on or before June 19, 1996, are 

subject to the regulations in 40 CFR Part 60, Subpart Ea. MWC facilities which commenced 

construction after September 20, 1994, or commenced modification or reconstruction after June 

19, 1996, are subject to the regulations in 40 CFR Part 60, Subpart Eb. This information is being 

collected to assure compliance with 40 CFR Part 60, Subpart Ea and Eb.

In general, all NSPS standards 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 NSPS.

Over the next three years, an average of 8 respondents of subpart Ea shall maintain a file 

of these measurements, and retain the file for at least two years following the date of such 

measurements, maintenance reports, and records. An average of 5 respondents of subpart Eb

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. We expect one plant 

(respondent) to startup in 2015 which will become subject to Subpart Eb. No additional 

respondent per year will become subject during the three year period of this ICR. Information 

required by the NSPS is necessary to ensure that emission standards are attained and that 

MWC’s are properly operated and maintained. 

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

without any “Terms of Clearance.”
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In the United States, there are approximately 13 MWC plants; all of which are privatelyowned, for-profit businesses. None of these facilities are owned by state, local, tribal, or the 

Federal governments. The burden to the “Affected Public” may be found in Table 1: Annual 

Respondent Burden and Cost – NSPS for Municipal Waste Combustors (40 CFR Part 60, 

Subparts Ea and Eb) (Renewal). The “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 – NSPS for Municipal Waste Combustors (40 CFR Part 

60, Subparts Ea and Eb) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years. In addition, section 114(a) states that the Administrator may require any 

owner/operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, organic, acid gas, and nitrogen oxide emissions from 

MWCs cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR 

Part 60, Subpart Ea and Eb.
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2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 standards 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 standards are being met. 

The performance test may also be observed.

The required quarterly and 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

Ea and Eb.

3(a) Nonduplication

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

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

state or local agency. If a state or local agency has adopted 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 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 (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations
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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 EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 

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

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted both the Energy Recovery Council at (202) 467-

6240 and the Solid Waste Association of North America at (800) 467-9262.

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 

the standards. EPA believes that the five year records retention requirement is consistent 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 
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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 MWCs. 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 Ea and Eb) SIC Codes NAICS Codes

Administration of Air and Water Resource and Solid 

Waste Management

9511 924110

Hazardous Waste Treatment and Disposal 4953 562211

Materials Recovery Facilities 4953 562920

Other Hazardous Waste Treatment and Disposal 4953 562219

Solid Waste Combustors and Incinerators 4953 562213

Solid Waste Landfills 4953 562212

 

4(b) Information Requested

(i) Data Items

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

Municipal Waste Combustors (40 CFR Part 60, Subpart Ea and Eb). 

A source must make the following reports:

Notifications
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Notifications

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

60.59b(a-c)

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

Notification of actual startup 60.7(a)(3), 60.59a(a), 

60.9b(c)

Notification related to siting analysis 60.59b(a)

Notification of initial performance tests 60.8(d)

Notification of initial performance tests results 60.8(a)

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

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

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

Reports

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

60.59b(f)

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

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

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

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

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

60.59a(g), 

60.59b(g)

Report excess emissions 60.59a(f), 

60.59b(h)

Report on continuous emission monitoring system (CEMS) 

demonstration and test data

60.8(a), 60.59b(f)

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

A source must keep the following records:

Recordkeeping

Initial performance tests and annual performance tests 60.59b(d)

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

Startup, shutdown, malfunction periods where the continuous 

monitoring system is inoperative

60.7(b)

Occurrence, duration of interruption in operation 60.7(b)

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

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

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

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

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

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

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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Method 19 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.
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Respondent Activities

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.

Perform site selection analysis.

Hold public meeting on site analysis and material separation plan.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

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

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

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 Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to

determine whether the pollution control devices are properly installed and 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 
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compliance and enforcement programs. The quarterly and semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Municipal Waste 

Combustors (40 CFR Part 60, Subparts Ea and Eb) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. 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 
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and reporting requirements is estimated to be 20,272 (Total Labor Hours from Table 1). These 

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

regulation, Agency knowledge and experience with the NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

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

The type of industry costs associated with the information collection activities in the 

subject standards 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 monitors and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

CEMs for 

Subpart Ea $60,000 0 $0 $8,972 8 $71,776

CEMs for 

Subpart Eb $60,000 0.33 $20,000 $8,972 5 $44,860

Total $20,000 $116,636

The total capital/startup costs for this ICR are $20,000. This is the total of column D in 

the above table. 
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The total operation and maintenance (O&M) costs for this ICR are $116,636. 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 $136,636. 

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 

$38,853. 

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%)

These rates are from the Office of Personnel Management (OPM), 2014 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 – NSPS for Municipal 

Waste Combustors (40 CFR Part 60, Subparts Ea and Eb) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

13 existing respondents will be subject to the standard. It is estimated that one respondent will 

become subject to Subpart Eb during the first year of the ICR period, but no additional 

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

table below, is 13 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

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-Ea 0 8 0 0 8

2-Ea 0 8 0 0 8

3-Ea 0 8 0 0 8

Average - Ea 0 8 0 0 8

1-Eb 1 4 0 0 5

2-Eb 0 5 0 0 5

3-Eb 0 5 0 0 5

Average - Eb 0.33 5 0 0 5

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 13. 

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

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of initial 

performance test for Ea 0 0 N/A 0

Notification of CMS 

demonstration for Ea 0 0 N/A 0

Compliance reports for Ea 8 1 N/A 8

Opacity reports for Ea (no 

excess emission) 6.4 1 N/A 6.4

Opacity reports for Ea (excess 

emission) 1.6 1 N/A 1.6

Report of daily weight of 

municipal solid waste (MSW) 

and fuel for Ea

8 4 N/A 32

Appendix F reports for Ea 8 4 N/A 32

Notification of 

construction/reconstruction for 

Eb

0.33 1 N/A 0.33

Notification of initial 

performance test for Eb 0.33 1 N/A 0.33

Notification of CMS 

demonstration for Eb 0.33 1 N/A 0.33

Initial compliance reports for 

Eb 0.33 1 N/A 0.33

Annual compliance reports for 

Eb 5 1 N/A 5

Semiannual excess emission 

reports Eb 5 2 N/A 10

Appendix F quarterly reports 

for Eb 5 4 N/A 20

Initial report on site selection 

analysis for Eb 0.33 1 N/A 0.33

Public meetings and comment 

responses for Eb 0.33 1 N/A 0.33

Total 117

The number of Total Annual Responses is 117. 

The total annual labor costs are $1,761,252. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Municipal Waste 
14

Combustors (40 CFR Part 60, Subparts Ea and Eb) (Renewal).

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 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 20,272. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost – NSPS for Municipal Waste Combustors (40 

CFR Part 60, Subparts Ea and Eb) (Renewal).

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

information is estimated to average 173 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $136,636. The 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 854

labor hours at a cost of $38,853. See Table 2: Average Annual EPA Burden and Cost – NSPS 

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

6(f) Reasons for Change in Burden

There is a decrease in the respondent burden, but an increase in the number of responses 

and the Agency burden. These changes are due to the following adjustments: 1) The number of 

sources subject to each Subpart was revised to reflect more recent information obtained through 

the Agency’s research within the MWC sector; 2) the number of sources required to submit 

initial notification and siting analysis was corrected to reflect this activity as a burden only for 

new sources, rather than for existing sources; 3) several mathematical errors in calculating 

burden costs were corrected; and 4) all estimates were updated using more recent labor rates. 

6(g) Burden Statement

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

is estimated to average 173 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 
15

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-2014-0045. 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 

Number EPA-HQ-OECA-2014-0045 and OMB Control Number 2060-0210 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and 

Eb) (Renewal)

Burden item

(A) 

Hours per

Occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Emission 

Test 

PersonHours per 

Occurrence

(I) 

Emission 

Testing 

Contractor 

PersonHours per 

Year 

(HxD) c

(J) 

Total Cost 

per year b

1. Applications N/A 

2. Survey and Studies N/A 

3. Reporting requirements 

 A. Read instructions 1 1 1 0.33 0.33 0.02 0.03 1 0.33 $63.55 

 B. Required activities

 Initial performance test for Eb d, e 24 1 24 0.33 7.92 0.40 0.79 1,053 347 $28,690.90 

 Repeat performance test for Eb f, e 24 1 24 0.07 1.68 0.08 0.17 1,053 73.71 $6,085.95 

 Demonstration/CEMS for Eb 24 1 24 0.33 7.92 0.40 0.79 470 155.1 $13,299.70 

 Repeat CEM demonstration Eb g 24 1 24 0.07 1.68 0.08 0.17 470 32.9 $2,821.15 

 Annual compliance test for Ea h, i 24 1 24 8 192 9.6 19.2 826 6,608 $550,256.90 

 Annual compliance test for Eb j, e 24 1 24 5 120 6 12 1,053 5,265 $434,710.56 

 Appendix F audit for Ea (in-situ) 125 8 1,000 0 0 0 0 0 0 $0

 Appendix F audit for Ea (extractive) 36 8 288 0 0 0 0 0 0 $0

 C. Create Information See 3B

 D. Gather information See 3B

 E. Write report 

 Notification of 

construction/reconstruction for Ea 2 1 2 0 0 0 0 0 0 $0

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

 Notification of initial performance test 

– Ea 2 1 2 0 0 0 0 0 0 $0
17

 Notification of CMS demonstration –

Ea 212000000 $0

 Notification of 

construction/reconstruction – Eb212 0.33 0.66 0.03 0.0700 $74.31 

 Notification of initial performance test – Eb

212 0.33 0.66 0.03 0.0700 $74.31 

 Notification of CMS demonstration –

Eb 212 0.33 0.66 0.03 0.0700 $74.31 

 Annual compliance reports for Ea 161 168 128 6.4 12.800 $14,411.26 

 Annual opacity report of no excess 

emission for Ea 

k

81

8

6.4 51.2 2.56 5.120

0 $5,764.51 

 Annual opacity report for excess 

emission for Ea 

l 16

1

16 1.6 25.6 1.28 2.56

0

0 $2,882.25 

 Report of daily weight of MSW and 

fuel for Ea 34

4

136

8

1088 54.4 108.8

0

0 $122,495.74 

 Appendix F reports for Ea 114 448 352 17.6 35.20

0 $39,630.98 

 Initial compliance report for Eb 401 40 0.33 13.2 0.66 1.320

0 $1,486.16 

 Annual compliance report for Eb 401 405 200 10 200

0 $22,517.60 

 Semiannual excess emission report Eb m 17

2

34

5

170 8.5 17

0

0 $19,139.96 

 Appendix F reports for Eb 

n

114 445 220 11 220

0 $24,769.36 

 Initial site selection analysis/report for 

Eb 270

1

270 0.33 89 4.46 8.91

0

0 $10,031.59 

 Public meeting and comment response 

for Eb 140

1

140 0.33 46.2 2.31 4.62

0

0 $5,201.57 

Subtotal for Reporting 

Requirements

3,124 12,483

$1,304,482.6

15,607

4. Recordkeeping requirements

A. Read instructions See 3A

 B. Plan activities See 4E 

 C. Implement activities See 4E 

D. Develop record system See 4E 

E. Time to enter information

Records of SSM for Ea 

o 1.5 104 156

8 1,248 62.4 124.80

0 $140,509.82 

Record emission measurements Ea 

o 1.5 104 156

8 1,248 62.4 124.80

0 $140,509.82 

Record of employee review of operation 

for Ea 

p

42

8

8

64 3.2 6.4

0

0 $7,205.63 
18

Record of emission rates, and 

computation tests for Eb q 

1.5 94

141

5

705 35.25 70.5

0

0 $79,374.54 

Record of SSM for Eb q

1.5 94

141

5

705 35.25 70.5

0

0 $79,374.54 

Record of employee review of operation 

for Eb r 4 28

5

40 2 4

0

0 $4,503.52 

Record amount of sorbent for Hg control 

for Eb 0.1 94 9.4 547 2.35 4.7 00 $5,291.64 

 F. Train personnel See 4E

 G. Audits See 4E

Subtotal for Recordkeeping 

Requirements

4,666 0

4,666

$456,769.52

TOTAL LABOR BURDEN AND 

COST 20,272 $1,761,252.12 

Assumptions:

a

 We have estimated that an average of 13 sources are subject to subparts Ea and Eb. Eight of these sources are currently subject to subpart Ea, with no additional sources

becoming subject to the regulation in the next three years. The remaining five sources are subject to subpart Eb. We have assumed that one additional

source will start up in 2015, which is the first year of the ICR renewal period. No additional sources will become subject to Eb. 

 b

 This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 per hour

 for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, Table 2. Civilian Workers, by Occupational

 and Industry groups. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for the benefit packages available to

 those employed by private industry.

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

d

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

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

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

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

h

 We have assumed that all of the 8 respondents for subpart Ea will have to complete an annual compliance test.

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

j

 We have assume that 5 respondents for subpart Eb will have to complete an annual compliance test.

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

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

m We have assumed that 5 of the respondents will be required to write semiannual excess emission report for Eb two times per year.

n

 We have assumed that 5 of the respondents will write the appendix F reports four times per year.

o

 We have assumed that all 8 respondents for subpart Ea will each take 104 hours to complete task.

p

 We have assumed that all respondents for subpart Ea will each take 4 hours two times per year to record employee review of operations.
19

q We have assumed that each of the 5 respondents will take 1.5 hours 94 times per year to enter information.

r

 We have assumed that each of the 5 respondents for subpart Eb will take four hours two times per year to enter employee review of operation information.
20

Table 2: Average Annual EPA Burden and Cost – NSPS for Municipal Waste Combustors (40 CFR Part 60, Subparts Ea and 

Eb) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrenc

es per 

plant per 

year

(C) 

EPA 

person 

hours per 

plant per 

year 

(AxB)

(D) 

Plants 

per 

year b 

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost, $ a

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

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

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

Repeat performance test for Eb c

12 1 12 0.07 0.84 0.04 0.08 $43.97

Report review for Ea

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

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

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

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

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

Review excess emission reports for Ea

 No excess emission report e

8 1 8 6.4 51.2 2.56 5.12 $2,679.81

 Excess emission report f

2 1 2 1.6 3.2 0.16 0.32 $167.49

Review quarterly appendix F reports for Ea h

0.5 4 2 8 16 0.8 1.6 $837.44

Review quarterly compliance report for Ea h

8 4 32 8 256 12.8 25.6 $13,399.04

Review annual compliance tests for Ea j

18 1 18 8 144 7.2 14.4 $7,536.96

Report review for Eb d

 Notification of construction 2 1 2 0.33 0.66 0.03 0.07 $34.54

 Notification of initial performance test 8 1 8 0.33 2.64 0.13 0.26 $138.18

 Notification of CEMS demonstration 5 1 5 0.33 1.65 0.08 0.17 $86.36
21

Review CEMS demonstration for Eb 40 1 40 0.33 13.2 0.66 1.32 $690.89

Review semiannual excess emission reports for 

Eb g

12 2 24 5 120 6 12 $6,280.80

Review of quarterly Appendix F reports for Eb 5 4 20 5 100 5 10 $5,234.00

Review annual compliance reports for Eb i

5 1 5 5 25 1.25 2.5 $1,308.50

Review siting requirements study for Eb k

24 1 24 0.33 7.92 0.40 0.79 $414.53

TOTAL ANNUAL BURDEN AND COST 854 $38,852.51 

Assumptions:

a.

 We have estimated that an average of 13 sources are subject to subparts Ea and Eb. Eight of these sources are currently subject to subpart Ea, with no additional sources

becoming subject to the regulation in the next three years. The remaining five sources are subject to subpart Eb (with one source startup in 2015).

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 Managerial rate (GS13, 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) 2014 General Schedule which excludes locality rates of pay

c

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

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

e.

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

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

g.

 We have assumed that all 5 respondents that are subject to subpart EB will review semiannual excess emission reports.

h.

 We have assumed that all 8 respondents that are currently subject to subpart Ea will have to review quarterly reports.

i

 We have assumed that all 5 respondents that are subject to subpart Eb will have to review annual compliance reports.

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

k

 All of the 5 respondents that are subject to subpart Eb will have to review the siting requirement’s study.