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 Emission 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 (CISWI) 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 CISWI unit 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 

Federal 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 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 U. S.

Environmental Protection Agency (EPA) regional office.

We estimate an average of 90 sources will be subject to the standard, and that no new 

respondents will be subject over the three-year period of this information collection request 
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(ICR). The estimated number of existing sources is based on the February 2011 regulatory

impact analysis (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-HQOAR-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 apply to sources commencing modification or reconstruction before August 7, 2013, 

we have revised the number of sources to 90 to account for sources modified or reconstructed in 

the two years 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 currently active ICR 

without any “Terms of Clearance.”

The “Affected Public” are CISWI units, all of which are owned by 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 

Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal). The “burden” to the Federal 

Government is attributed entirely to work performed by either Federal employees or government 

contractors, 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) 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:
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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. 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;
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 CISWI units either cause or contribute 

to air pollution that may reasonably 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 ensures 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 times. 

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 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 operation/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. Specifically, 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 that 
5

subpart DDDD is being properly 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 requested 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 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, 

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 ICR 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 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. 

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 developing this ICR, 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 ICR 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 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 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 (CBI) (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 CISWI units. The 

United States Standard Industrial Classification (SIC) codes and corresponding North American 

Industry Classification System (NAICS) codes for CISWI unit owners and operators are 

provided in the following table:
7

Standard (40 CFR Part 60, Subpart 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 by 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 physical or operational change. 60.7(a)(4)

Notification of demonstration date of continuous monitoring system 

performance.

60.7(a)(5)

Notification of anticipated date for conducting opacity observations. 60.7(a)(6)

Notification of use of continuous opacity monitoring system 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. 60.2595
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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 years. 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 CISWI unit operators who have completed the 

operator training requirements.

60.2740(h)

Maintain records of phone and/or pager numbers of CISWI unit 

operators having met the operator qualification criteria.

60.2740(i)

Maintain records of monitoring device calibrations. 60.7(f), 60.2740(j)
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Recordkeeping

Maintain records of equipment vendor specifications and operation 

and maintenance requirements for incinerators, emission controls, 

and monitoring equipment.

60.2740(k)

Maintain records of site-specific procedures; CISWI unit 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 daily 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 systems parameter 

measurements.

60.7(f), 60.2740(o)

Maintain records indicating date, time, and duration of bypass 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

year.

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 records 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)
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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 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 

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.

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.
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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). 

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 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 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.

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). 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 businesses. 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. 
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 provisions 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 systems (CEMS).

2. The owner or operator is allowed to skip two annual performance tests for a pollutant 

if previous performance tests demonstrate compliance.

3. Deviation reports only 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 DDDD) 

(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 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
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This ICR uses the following labor rates: 

Managerial $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 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 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 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 (O&M) costs 

are the ongoing costs to maintain the monitor(s) 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)

Wet scrubber 1

$2,240 0 $0 $0 0 $0

Annual stack testing 2

$0 0 $0 $12,500 90 $1,125,000

Continuous parameter 

monitoring (including 

bypass stack) 3

$0 0 $0 $211 90 $18,990

TOTAL $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 = $2,113; 

$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 ICR are $0. This is the total of column D in the 

above table. 

The total O&M costs for this ICR 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 ICR is estimated to be $1,143,990. These are the costs

of recordkeeping.

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 

$46,642. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates 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. 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 ICR, on average over the next three years, approximately

90 existing respondents will be subject to the standard. No new respondents will become 

subject. The overall average number of respondents, as shown in the table below, is 90 per year.

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

years covered by this ICR. 

Number of Respondents
15

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 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

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 90.

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

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 190 1 0 90
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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

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 reports 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), respectively, 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.

The total annual capital/startup and O&M costs 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 

currently identified in the OMB Inventory of Approved Burdens. The change from the most 

recently 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 solely to O&M activities, we have revised the ICR to reflect these as O&M costs, 

resulting in an apparent decrease in the total respondent labor burden.

Second, this ICR revises the number of respondents based on more recent information 

obtained from a 2011 Regulatory Impact Analysis (RIA) conducted by EPA. The previous ICR 

estimated 97 existing sources were subject to the standard; however, the RIA indicates 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 ICR. As 

described above, the previous ICR 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 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 
18

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-2012-0685. 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 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) 566-1752. 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-2012-0685 and OMB Control Number 2060-0451 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical 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 

personhours 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)

Management 

person

hours per 

year (Ex0.05)

Clerical

person

hours 

per year 

(Ex0.10)

Total cost per 

year 

($) b

1. Applications

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 monitoring 

(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 3E
20

Burden Item

A B C D E F G H

Technical 

personhours 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)

Management 

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 offsite 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 $24,052.25 
21

Burden Item

A B C D E F G H

Technical 

personhours 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)

Management 

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 which 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 3,094.66 $299,650.92 
22

Burden Item

A B C D E F G H

Technical 

personhours 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)

Management 

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

Assumptions:

a.

 We estimate that an average of 90 existing respondents and zero new respondents 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 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.

c.

 This activity is based on a one-time cost 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 exceedance 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 

personhours 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)

Management 

hours per 

year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($) a

1. Applications N/A

2. Read rule requirements 16 0 0 0 0 0 0 $0

3. Required Activities

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 rates 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.