**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units ( 40**  **CFR Part 60, Subpart DDDD) (Renewal)**  **1. Identification of the Information Collection 1(a) Title**  **of the Information Collection** Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units ( 40 CFR Part 60, Subpart DDDD) (Renewal), EPA ICR Number 1927.06, OMB Control Number 2060

- 0451 **1(b) Short Characterization/Abstract** The Emis sion Guidelines for Commercial and Industrial Solid Waste Incineration Units ( 40 CFR part 60, subpart DDDD ) were proposed on November 30, 1999 , and promulgated on January 30, 2001

. The guidelines were recently amended on February

7, 2013 , to clarify definitions, references, applicability , and compliance issues and to establish effective dates. These guidelines fulfill the requirements of sections 111 and 129 of the Clean Air Act (CAA), and affect the administrator of an air quality program in a state or United States protectorate with one or more existing commercial and industrial solid waste incineration (CI SWI) units. The emission guidelines apply to sources commencing construction on or before June 4, 2010 or to sources commencing modification or reconstruction between June 1, 2001 and August 7, 2013

. The guidelines do not apply directly to CISWIunit owners and operators , since they are implemented through state implementation plans (SIP). If a state does not develop, adopt, and submit an approved state plan, or if a state’s plan is not approved, the EPA must promulgate a F ederal implementation plan to implement the emission guidelines in a state without its own SIP. This information is being collected to assure compliance with 40 CFR part 60 , subpart DDDD

. 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 an d duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring s ys tem 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional offic e. W e estimate an average of 90 sources will be subject to the standard , and that no new respondents will be subject over the three

- ye ar period of this information collection request2

(I CR). The estimate d number of existing source s is based on the February 2011 regulatory impact anal ys is (RIA) conducted in support of proposed revisions to the existing emission guidelines. The RIA can be found in the public docket under Docket ID Number EPA

- HQ

OAR

- 2003

- 0119. The RIA estimated 88 existing sources were subject to the standard in 2011 , and that the industry

would grow at a rate of one new source per year. Since the emission guidelines appl y to sources commencing modification or reconstruction before August 7, 2013 , w e have revised the number of source s to 90 to account for sources modified or reconstructed in the two ye ars between RIA publication (i.e., 2011 ) and August 7, 2013

. Starting on this date, no new sources will be subject to the standard

. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any

“Terms of Clearance.” The “Affected Public” are CI SWIunits, all of which are owned b y private, for

- profit businesses. The “burden ” to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste In cineration Units (40 CFR Part 60, Subpart DDDD) (Renewal)

. The “burden ” to the Federal Government is attributed entirely to work performed by either F ederal employees or government contractor s , and may

be found below in Table 2: Average Annual EPA Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal).
**2. Need for and Use of the Collection 2(a) Need** **/Authority for the Collection** The EPA is charged under section 111(d)(1) of the Clean Air Act (CAA), as amended, to:

**. . .** prescribe regulations which shall establish a procedure similar to that provided by

section 110 under which each State shall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant (i ) for which air quality criteria have not been issued or which is not included on a list published under section 108(a) **. . .** but (ii) to which a standard of performance under this section would apply if such existing source were a new source, and (B) prov ides 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:3 The Administrator shall establish performance standards and other requirements pursuant to section 111 and this section for each category of solid waste incineration units. Such standards shall include emissions limitations and other requirements applicable to new units and guidelines (under section 111(d) and this section) and other requirements applicable to existing units. Section 129(a)(2) states: Standards applicable to solid waste incineration units promulgated under section 111 and this section shall reflect the maximum degree of reduction in emissions of air pollutants listed under section (a)(4) that the Administrator, taking into consideration the cost of achieving such emission reduction, and any non - air quality health and environmental impacts and energy requirements, determines is achievable for new or existing units in each category

. Section 129(b)(1) states: Performance standards under this section and section 111 for solid waste incineration units shall include guidelines promulgated pursuant to section 111(d) and this section applicable to existing units. S uch 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), subse ction (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 ba sis to: (A) establish and maintain such records; (B) make such reports;4 (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods and in such manner as the Administer shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3); and (G) provide such other information, as the Administrator may

reasonably

require; **. . . .** In the Administrator's judgment, emissions from CI SWIunits either cause or contribute to air pollution that may

reasonabl y be anticipated to endanger public health and/ or welfare. Therefore, the emission guidelines were promulgated for this source category at 40 CFR part 60, subpart DDDD

. **2(b) Practical Utility/Users of the Data**  The recordkeeping and reporting requirements in the standard ensure s compliance with the applicable regulations which where 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 tim es. 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 properl y installed and operated and the standard is 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 operati on/maintenance procedures and for compliance determinations. The information will be used by enforcement and compliance authorities to ensure that the requirements of the state or Federal plans are implemented and that the subject facilities comply with the plans on a continuous basis. Specificall y, the information will be used by the authorities to: (1) identify existing sources subject to the standards; (2) ensure those existing sources have a control plan to achieve compliance by the final compliance date; (3) ensure that5

subpart DDDD is being properl y applied; ( 4) ensure compliance with the emission standards; and (5) ensure, on a continuous basis, that the operating parameters established during the initial stack test are not exceeded.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The reque sted recordkeeping and reporting are required under 40 CFR part 60, subpart DDDD

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the informatio n is sent directl y 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 cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 77 FR 63813) on October 17, 2012 . 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 Sy stem (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. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply

. In dev eloping this I CR, EPA contacted : 1) the Solid Waste Association of North America (SWANA) , at (240) 494

- 2253 ; and 2 ) the National Solid Waste Management Association (NSWMA) , at (202) 364

- 3773. EPA did not receive any comments from the consultations. It is our policy

to respond after a thorough review of comments received since the last I CR renewal as well as those submitted in response to the first Federal Register notice.6

**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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute o f limitations on which the permit program is based. Th e retention of records for five years allow s 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 fo und that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

. **3(f) Confidentiality** Any information submitte d to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1 976; 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 CI SWI units . The United States Standard Industrial Classification (SI C) codes and corresponding North American Industry Classification Sy stem (NAICS) codes for CI SWIunit owners and operators are provided in the following table :7

**Standard (**  **40 CFR P**  **art 60, S**  **ubpart DDDD )**  **SIC Codes NAICS Codes**  Manufacturers of chemicals and allied products 28 325 Manufacturers of electronic equipment 34 325 Manufacturers of wholesale trade, durable goods 25, 36 337, 421 Manufacturers of lumber and wood furniture 24 321 Law enforcement agencies 9229 922 Department of Defense (labs, military bases, munition facilities) 9711 928 Research Centers 8221 6113 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD). A source must make the following reports: **Notifications/Reports** Notification of construction/reconstruction

. 60.7(a)(1) Notification of initial startup date

. 60.7(a)(3) Notification of phys ical or operational change

. 60.7(a)(4) Notification of demonstration date of continuous monitoring sy stem performance

. 60.7(a)(5) Notification of anticipated date for conducting opacity observations

. 60.7(a)(6) Notification of use of continuous opacity monitoring s ys tem data results to determine compliance with opacity standard during performance testing. 60.7(a)(7)
Notification of final control plan

. 60.2575 , 60.2600 , 60.2610
Notification of final compliance

. 60.2575 , 60.2605 , 60.2610 Notifications until increments of progress are met. 60.25958 **Notifications/Reports** Notification of closure. 60.2615 Waste management plan. 60.2755 Initial and subsequent performance test reports. 60.2760 Annual report. 60.2765 , 60.2770 Emission limitation or operating limit deviation report. 60.2775 , 60.2780 Qualified operator deviation notification. 60.2785(a)(1) Qualified operator deviation status report. 60.2785(a)(2) Qualified operator deviation notification of resumed operation. 60.2785(b)
Notification of waste

- to

- fuel switch. 60.2710(a)(4) , 60.2790(b) Notification of air curtain incinerator closure. 60.2855 A source must keep the following records: **Recordkeeping** Maintain records of startups, shutdowns, or malfunctions. 60.7(b) Retain records for five ye ars. 60.2740 Maintain calendar date of each record. 60.2740(a) Maintain records of operating parameters. 60.2740(b) Maintain records of dates when deviation from operating limits has occurred, including reasons for deviations and descriptions of corrective actions taken. 60.2740(e)

Maintain records of initial, annual, and any subsequent performance tests. 60.2740(f)

Maintain records of CI SWIunit operators who have completed the operator training requirements. 60.2740(h) Maintain records of phone and/or pager numbers of CI SWIunit operators having met the operator qualification criteria. 60.2740(i) Maintain records of monitoring device calibrations. 60.7(f), 60.2740(j)9 **Recordkeeping** Maintain records of equipm ent vendor specifications and operation and maintenance requirements for incinerators, emission controls, and monitoring equipment. 60.2740(k)

Maintain records of site

- specific procedures; CI SWIunit operator review of site

- specific procedures; and operator training documentation and contact information. 60.2660(a), 60.2740(l), 60.2660(c), 60.2740(g)

Maintain records of dail y log of quantity and types of waste burned. 60.2740(m) Maintain records of annual inspections of air pollution control devices, any required maintenance, and any repairs not completed within the established timeframe. 60.2740(n)

Maintain records of continuous monitoring sy stems parameter measurements. 60.7(f) , 60.2740( o ) Maintain records indicating date, time, and duration of by pass stack use. 60.2740(p) Maintain annual records showing previous stack test emission was below 75 percent of applicable limit and that no source operation changes occurred that would increase emissions within the past ye ar. 60.2740(q)

Maintain records of occurrence and duration of process equipment, air control, or monitoring equipment malfunctions. 60.2740(r)
Maintain records of all required maintenance performed on air pollution control and monitoring equipment. 60.2740(s)

Maintain re cords of actions taken to minimize emissions from process, air pollution control, and monitoring equipment during periods of malfunction. 60.2740(t)

Maintain records showing how non

- hazardous secondary materials meet legitimacy

criteria or petition process requirements, or showing how materials are listed as non

- wastes. 60.2740(u)

Maintain records of criteria establishing unit qualification as a small power production facility, and that proposed waste materials are homogeneous. 60.2740(v)

Maintain records of criteria establishing unit qualification as a cogeneration facility , and that proposed waste materials are homogeneous. 60.2740(w)10

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 recordke eping at a plant site. Also, regulatory

agencies , in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems 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 pollutant control devices

. Perform initial and annual performance tests. 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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. Currently , sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has s ignificantl y reduced the burden associated with monitoring and recordkeeping.11

**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, anal yz e, and maintain data in the Online Tracking Information System (OTI S). Observe compliance tests (optional). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y with the emission standard , and to 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.
In formation c ontained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. Th e records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). A RIA published in February

2011 by EPA estimated that 88 entities (from a total of 90) were subject to the regulation. Of these facilities, ten were considered to be small busine sses. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities.12

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. The rules contain provisi ons that reduce the impact of the rule on all regulated entities which includes small entities. These are: 1. Operating parameter monitoring is required instead of continuous emissions monitoring sy stems (CEMS). 2. The owner or operator is allowed to skip tw o annual performance tests for a pollutant if previous performance tests demonstrate compliance. 3. Deviation reports onl y required if there is a deviation, otherwise reporting is annual. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1 : Annual Respondent Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDD D) (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 I CR. The individual b urdens 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 collectio n 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 requirement s is estimated to be 18,061 hours ( Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the emission guidelines , the previously

approved ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs** 13

This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 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 ty pe 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. Th e capital/startup costs are one

- ti me costs when a facility becomes subject to the regulation. The annual operation and maintenance (O &M) costs are the ongoing costs to maintain the monitor(s) and other costs su ch 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 Respondent s (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)
Wet s crubber 1 $2,240 0 $ 0 $0 0 $0 Annual stack testing 2 $0 0 $0 $12,500 90 $1,125,000 Continuous parameter mo nitoring (including bypass stack) 3 $0 0 $0 $211 9 0 $18,990
TO TAL $ 0 $1,143,990
1 Total capital cost of parameter monitoring for wet scrubbers minus planning and equipment selecting cost equals: $18,786

- $800 = $17,986. Based on 0.11746 capital recovery factor, 10 percent interest rate, and 20 year lifetime of the units = $2,1 13; $2, 113 x 1.06 cost adjustment = $2,240. 2 Assume 125 contractor hours per respondent and an average contractor labor rate of $100 per hour; 125 x $100 = $12,500. 3 Based on the memorandum titled " Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs)

- Methodology and Assumptions (A

- 91

- 61,IV

- B

- 66) ," O&M cost = $1,693 x 0.11746 = $199; $199 x 1.06 cost adjustment = $211. The total capital/startup costs for this I CR are $0 . This is the total o f column D in the above table. The total O&M costs for this I CR are $1,143,990

. This is the total of column G.14

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $1,143,990

. These are the costs of recordke eping

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the e xamination 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 $ 46,642

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2 : Average Annual EPA Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 90 existing respondents will be subject to the standard. No new respondents will become subject. The overall average number of respondent s, as shown in the table below, is 90 per ye ar. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.

**Number of Respondents**15

Year (A) Number of Ne w 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 90 0 0 90
1 0 90 0 0 90 3 0 90 0 0 90 Average 90 90

1 New respondent include sources with constructed, reconstructed and modified affected facilities C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 90

. The total number of annual responses per ye ar 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

Construction/reconstruction notification 0 1 0 0 Startup notification 0 1 0 0 Demonstration date of continuous monitoring system performance notification 0 1 0 0 Anticipated date for conducting opacity observations notification 0 1 0 0 Use of continuous opacity monitoring system data notification 0 1 0 0 Final control plan notification 0 1 0 0 Final compliance notification 0 1 0 0 Waste management plan 0 1 0 0 Initial performance test report 0 1 0 0 Annual report 1 90 1 0 9016 **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

Emission limitation or operating limit deviation report 2 9 2 0 18 Qualified operator deviation notification 2 9 1 0 9 Qualified operator deviation status report 2 9 1 0 9 Qualified operator deviation notification of resumed operation 2 9 1 0 9
Total 135 1 Annual report s are not required until the second year that units are in operation; therefore, annual reports will only apply to existing sources (i.e., 90 respondents). 2 Assume that these activities will apply to 10 percent of existing sources

. The number of Total Annual Responses is 135

. The total annual labor costs are $ 1,748,799

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units ( 40 CFR Part 60, Subpart DDDD) (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) , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 18,061 hours at a cost of $1,748,799

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 134 hours per response

. Th e total annual capital/startup and O&M cos ts to the regulated entity are $ 1,143,990

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.17 **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 1,035 labor hours at a cost of $ 46,642 . See below Table 2 : Average Annual EPA Burden and Cost

– Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). **6(f) Reasons for Change in Burden**  There is a change in the total estimated respondent and Agency burden and cost as currentl y identified in the OMB Inventory of Approved Burdens. The change from the most recentl y approved ICR is due to several reasons. First, the previous ICR included contractor labor costs associated with annual stack testing and continuous parameter monitoring as a respondent burden. Since the contractor labor costs apply

solel y to O&M activities, we have revised the I CR to reflect these as O&M costs, resulting in an apparent decrease in the total respondent labor burden. Second, this I CR revises the number of respondents based on more recent information obtained from a 2011 Regulatory Impact Analy sis ( RIA) conducted by EPA. The previous ICR estimated 97 existing sources were subject to the standard ; however , the RIA indicate s there are approximately 90 existing sources. This ICR reflects the most recent information obtained from the 2011 RIA, and contributes to the apparent decrease in the respondent and Agency labor burdens. Finally , there is a slight increase in Agency burden costs from the most recently approved ICR due to the use of updated labor rates. This ICR references labor rates from the Bureau of Labor Statistics to calculate respondent burden costs and references labor rates from OPM to calculate Agency

burden costs. There is an apparent increase in the O&M costs as compared to the previous I CR. A s described above, the previous I CR included contractor labor costs associated with annual stack testing and continuous parameter monitoring as a respondent burden. The revision to reflect these activities as O&M costs resulted in the apparent increase of the total O&M cost. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 134 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying in formation, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of informati on; search data18

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 f

or minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0685. 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 sy stem , 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 2012

- 0685 and OMB Control Number 2060

- 0451 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no s tatistical methods were used in collecting this information.19

**Table 1 : Annual Respondent Burden and Cost** 

**– Emission Guidelines for Commercial and Industrial Solid Waste Incineration**  **Units (40 CFR Part 60, Subpart DDDD) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per respondent per**  **year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**person hours per**  **year (CxD)**  **Managem ent** 

**person hours per**  **year (Ex0.05) Clerical** 

**person hours**  **per year (Ex0.10)**  **Total cost per**

**year ($)**  **b**

1. A pplications 2. Survey and Studies N/A 3. Reporting Requirements A. Read Instructions c, d 16 1 16 0 0 0 0 $ 0 B. Required Activities 1) Initial requirements c a) Initial stack test 16 1 16 0 0 0 0 $ 0 b) Establish and teach operator qualification course 64 1 64 0 0 0 0 $ 0 c) Obtain operator qualification 72 1 72 0 0 0 0 $ 0 d) Establish operating parameters (maximum and minimum) 160 1 160 0 0 0 0 $ 0 e) Continuous parameter mo nitoring (including by

-pass stack) e 9 1 9 0 0 0 0 $ 0 2) Periodic requirements a) Annual stack test and test report 12 1 12 90 1,080 54 108 $ 120,261.24 b) Annual refresher operator training course 12 1 12 90 1,080 54 108 $ 120,261.24 c) Annual review of site

- specific information 8 1 8 90 720 36 72 $ 80,174.16 d) Continuous parameter monitoring (including by

-pass stack) f 83 1 83 90 7,470 373.5 747 $ 831,806.91 C. Create Information See 3B D. Gather Information See 3E20

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per respondent per**  **year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**person hours per**  **year (CxD)**  **Managem ent** 

**person hours per**  **year (Ex0.05) Clerical** 

**person hours**  **per year (Ex0.10)**  **Total cost per**

**year ($)**  **b**

E. Report Preparation 1) Control plan 40 1 40 0 0 0 0 $ 0 2) Notification of final compliance 4 1 4 0 0 0 0 $ 0 3) Report of initial performance test 8 1 8 0 0 0 0 $ 0 4) Siting analysis for new units only (established values for site

- specific operating parameters) 8 1 8 0 0 0 0 $ 0 5) Waste management plan 160 1 160 0 0 0 0 $ 0 6) Annual Report: g a) Site specific operating parameters 8 1 8 90 720 36 72 $ 80,174.16 b) Emissions/parameter exceedances and malfunctions See 3E c) Results of stack tests conducted during the year See 3B d) Statement of no exceedances 8 1 8 90 720 36 72 $ 80,174.16 e) Documentation of use of by

-pass stack See 3B f) Documentation for periods when all qualified operators were unavailable for more than 8 hours 8 1 8 90 720 36 72 $ 80,174.16 7) Status report for operators that are off

site for more than 2 weeks h 8 1 8 9 72 3.6 7.2 $ 8,017.42 8) Corrective action summary for operators that are off

- site for more than 2 weeks h 8 2 16 9 144 7.2 14.4 $ 16,034.83 9) Qualified operator deviation notification of resumed operation 8 1 8 9 72 3.6 7.2 $ 8,017.42 10) Semiannual report of emissions/parameter exceedances i 12 2 24 9 216 10.8 21.6 $ 24,052.2521

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per respondent per**  **year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**person hours per**  **year (CxD)**  **Managem ent** 

**person hours per**  **year (Ex0.05) Clerical** 

**person hours**  **per year (Ex0.10)**  **Total cost per**

**year ($)**  **b**

**Subtotal for Reporting Requirements 14,966**  **.1 $**  **1,449,147.94** 4. Recordkeeping Requirements A. Read Instructions See 3A B. Plan Activities See 3B C. Implement Activities See 3B D. Develop Record System N/A E. Record Information 1) Records of operating parameters See 3B 2) Records of periods for w hich minimum amount of data on operating parameters were not obtained 0.5 52 26 9 234 11.7 23.4 $ 26,056.6 3) Records of malfunction of the unit 1.5 1 1.5 9 13.5 0.68 1.35 $ 1,503.27 4) Records of exceedances of the operating parameters 1.5 1 1.5 9 13.5 0.68 1.35 $ 1,503.27 5) Records of stack tests See 3E 6) Records of persons who have reviewed operating procedures 1 1 1 90 90 4.5 9 $ 10,021.77 7) Records of persons who have completed operator training 1 1 1 90 90 4.5 9 $ 10,021.77 8) Records of persons who meet operator qualification criteria 1 1 1 90 90 4.5 9 $ 10,021.77 9) Records of monitoring device calibration See 3B 10) Records of site

- specific documentation 24 1 24 90 2,160 108 216 $ 240,522.48 F. Personnel Training See 3B G. Time for Audits N/A **Subtotal for Recordkeeping Requirements 3,09**  **4.66 $**  **299,650.92**22

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per respondent per**  **year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**person hours per**  **year (CxD)**  **Managem ent** 

**person hours per**  **year (Ex0.05) Clerical** 

**person hours**  **per year (Ex0.10)**  **Total cost per**

**year ($)**  **b**

**TOTAL ANNUAL BURDEN AND COST (rounded** **) 18,061**  **$ 1,748,799** 
**Assu mptions:**  a. We estimate that an average of 90 existing respondents and zero new respondent s per year will be subject to the rule over the three

- year period of this ICR. b. This ICR uses the following labor rates: $100.23 for technical, $121.44 for managerial, and $50.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occ upational and industry group.” The rates are from column 1, “T otal compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those em ployed by private industry.
c. This activity is based on a one

- time c ost only. d. This cost is incurred by a facility regardless of the number of affected units at the plant.
e. Based on the “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs)

- Methodology and Assumptions (A

- 91

- 61,IV

- B

- 66)," we assume 9 hours (($300 for planning + $500 for selection)/$89.94 per hour = 9 hours). f. Based on the "Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs)

- Methodology and Assumptions (A

- 91

- 61, IV

- B

- 66)," respondents spend 83 hours for reporting. g. Respondents make one combined annual report per year. h. Assume that 10 percent of facilities will not have a qualified operator available for more than two weeks at least once a year, and that two corrective action summaries will be required. i. Assume that 10 percent of the facilities will have an exceedanc e during the year.23

**Table 2 : Average Annual EPA Burden and Cost** 

**– Emission Guidelines for Commercial and Industrial Solid Waste Incineration**  **Units (40 CFR Part 60, Subpart DDDD) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per respondent per**  **year Technical** 

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year Technical** 

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **a**

1. A pplications N/A 2. Read rule requirements 16 0 0 0 0 0 0 $ 0 3. Required A ctivities Report Reviews 1) Review control plan 8 1 8 0 0 0 0 $ 0 2) Review notification of final compliance 8 1 8 0 0 0 0 $ 0 3) Review waste management plan 8 1 8 0 0 0 0 $ 0 4) Review initial stack test report 40 1 40 0 0 0 0 $ 0 5) Review annual compliance report 8 1 8 90 720 36 72 $ 37,313.64 6) Review semi

- annual excess emission and parameter exceedance report b 16 1 16 9 144 7.2 14.4 $ 7,462.73 7) Review status reports and corrective action summary for operators off

- site b 4 1 4 9 36 1.8 3.6 $ 1,865.68 **TOTAL ANNUAL BURDEN AND COST ( rounded** **) 1,035**  **$ 46,642**  Assumptions:
a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These r ates are from the Office of Personnel Management (OPM), 2011 General Schedule, which excludes locality , rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. b. We assume that 10 percent of the facilities will have exceedance reports and operator off

- site reports.