SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR 

Part 60, Subpart CCCC) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, 

Subpart CCCC) (Renewal), EPA ICR Number 2384.03, OMB Control Number 2060-0662

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Commercial and Industrial Solid 

Waste Incineration (CISWI) Units were proposed on April 29, 2010, promulgated on March 21, 

2011, and last-amended on February 7, 2013. The regulation at subpart CCCC amended the 

2000 CISWI NSPS by re-establishing emission limits and expanding the rule to cover additional 

four CISWI subcategories: energy recovery units; waste burning kilns; burn-off ovens; and 

small, remote incinerators. Subpart CCCC applies to new CISWI units that commenced 

construction after June 4, 2010, or commenced reconstruction or modification after August 7, 

2013. The subpart does not affect CISWI units that undergo physical or operational changes 

primarily to comply with the Emission Guidelines at subpart DDDD. This information is being 

collected to assure compliance with 40 CFR part 60, subpart CCCC.

In general, all NSPS standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS. 

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.

The population of CISWI units has been declining for several years. No new CISWI

units are being constructed, even in the absence of regulations, because other waste disposal 

alternatives, such as landfilling, are usually more economical. However, for the small remote 

incinerator subcategory, we realize that other waste disposal alternatives may be unavailable, and 

therefore some new units may be constructed or older units replaced as their useful life expires. 

For all other subcategories, the cost of complying with the NSPS makes it even more likely that 

sources will select an alternative method of waste disposal and no new units in these 

subcategories will be constructed.
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Over the next three years, we estimate an average of 4 respondents per year will be 

subject to these standards, and 1 additional respondent per year will become subject to these 

same standards. This is based on the assumption that one new small, remote incinerator is 

being constructed per year since these regulations were proposed. 

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

without any “Terms of Clearance.”

The “Affected Public” are owners and operators of new CISWI units. The “burden” to 

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

NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, 

Subpart CCCC) (Renewal). The Federal Government burden 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 – NSPS for Commercial and Industrial Solid 

Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

to establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

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

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

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

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

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

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

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

compliance certifications in accordance with Section 114(a)(3); 
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and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, particulate matter (PM), dioxins/furans, hydrogen 

chloride (HCl), cadmium (Cd), lead (Pb), mercury (Hg), carbon monoxide (CO), nitrogen oxides 

(NOx) and sulfur dioxide (SO2) emissions from CISWI units cause or contribute to air pollution 

that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS

were promulgated for this source category at 40 CFR part 60, subpart CCCC.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

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

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

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

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform either the Agency or its 

delegated authority when a source becomes subject to the requirements of these regulations. 

The reviewing authority may then inspect the source to check if the pollution control devices are 

properly installed and operated, leaks are being detected and repaired, and these standards are

being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart

CCCC.

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 exists.
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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 (78 FR 35023) on June 11, 2013. 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 EPA's Office of Compliance. OTIS is EPA’s database for the 

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

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

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

comment on the burden associated with the standards as they were being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the Alaska Oil and Gas 

Association, at (907) 279-1481; and 2) the National Waste & Recycling Association, at (800) 

424-2869.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with

Part 70 permit program and the five-year statute of limitations on which the permit program is 
5

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 owners and 

operators of CISWI units. The United States Standard Industrial Classification (SIC) codes for 

the respondents affected by the standard and the corresponding North American Industry

Classification System (NAICS) are listed in the table below: 
6

40 CFR Part 60, Subpart CCCC SIC Codes NAICS Codes

Chemical Manufacturing 2865, 2869, 2813, 2879, 2851, 2899, 

2891, 2844, 2893, 2892

325

Wholesale Trade, Durable Goods 5012, 5013, 5014, 5015, 5021, 5023, 

5031, 5032, 5033, 5039, 5043, 5044, 

5045, 5046, 5047, 5048, 5049, 5051, 

5052, 5063, 5064, 5065, 5072, 5074, 

5075, 5078, 5082, 5083, 5084, 5085, 

5087, 5088, 7389, 5091, 5092, 5093, 

5094, 5099, 7822

421

Wood Product Manufacturing 2429, 2441, 2448, 2449 321

Furniture and Related Product 

Manufacturing 

2432, 5712, 2515, 2591 337

4(b) Information Requested

(i) Data Items

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

Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart 

CCCC). 

A source must make the following reports:

Notifications/Reports

Preconstruction report

• Statement of intent to construct

• Anticipated date of commencement of construction

• Documentation for siting requirements

• Waste management plan

• Anticipated date of initial startup

60.2190(a)-(e)

Startup notification 60.2195(a)-(e)

Initial test report 60.2200

Annual compliance report 60.2205, 60.2210

Emission limitation or operating limit deviation report 60.2215, 60.2220

Qualified operator deviation notification 60.2225(a)(1)

Qualified operator deviation status report 60.2225(a)(2)
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Notifications/Reports

Qualified operator deviation notification of resumed operation 60.2225(b)

A source must keep the following records:

Recordkeeping

Records of operating parameters 60.2175(b), (p)

Records of malfunction of the unit 60.2175(s), (u)

Records of exceedances of the operating parameters 60.2175(e)

Records of stack tests 60.2175(f)

Records of siting analysis 60.2175(g)

Records of persons who have reviewed operating procedures 60.2175(h)

Records of persons who have completed operator training 60.2175(i)

Records of persons who meet operator qualification criteria 60.2175(j)

Records of monitoring device calibration and inspection 60.2175(k), (o)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

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

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

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

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for Hg, Pb, Cd, HCl, PM, CO, dioxins/furans, 

NOx, and SO2. 

Perform initial performance test, and repeat performance tests if necessary.
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Respondent Activities

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. 

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

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

determine whether the pollution control devices are properly installed and operated. 
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Performance test reports are used by the Agency to discern a source’s initial capability to 

comply with the emission standard, and note the operating conditions under which compliance 

was achieved. Data and records maintained by the respondents are tabulated and published for 

use in compliance and enforcement programs. The semiannual reports are used for problem 

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

determinations.

Information contained in the reports is 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

There are no small entities (i.e., small businesses) affected by this regulation. We expect 

the NSPS will only affect units in the small remote incinerator subcategory, which will consist 

primarily of large oil exploration and development entities. 

The NSPS does not contain any provisions reserved exclusively for the benefit of small 

entities. However, the NSPS does contain provisions that reduce the impact on all regulated 

entities, which would include any small entities (in the unlikely event that any new CISWI units 

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

if all performance tests over the previous three years show compliance. Deviation reports are 

required only if there is a deviation, otherwise reporting is annual. 

The Agency considers these to be the minimum requirements needed to ensure 

compliance and, therefore, cannot reduce them further for small entities. To the extent that 

larger businesses can use economies of scale to reduce their burden, the overall burden will be 

reduced.

5(d) Collection Schedule

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

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

Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 
10

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

concept of burden under the Paperwork Reduction Act. Wherever 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 1,036 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 NSPS program, the 

previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

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

2013, “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 costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.
11

(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)

Bag Leak 

Detectors $3,500 1 $3,500 $9,700 4 $38,800

CO CEMS $12,600 1 $12,600 $41,400 4 $165,600

ACI Monitors $0 1 $0 $4,200 4 $16,800

Stack Tests $55,000 1 $55,000 $14,533 4 $58,132

Postage for 

Performance Tests $7.5 1 $7.5 $7.50 4 $30

Postage for 

Semiannual reports $0 0 $0 $15 0.4 $6

Total $71,108 $279,368

The total capital/startup costs for this ICR are $71,108. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $279,368. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $350,476. These are 

recordkeeping costs. 

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 

$15,817. 

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%)
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These rates are from the Office of Personnel Management (OPM), 2013 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial 

and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) 

(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 4 

existing respondents will be subject to the standard. It is estimated that an additional 1

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below, is 5 per year. 

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

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 3 0 0 4

2 1 4 0 0 5

3 1 5 0 0 6

Average 1 4 0 0

5

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 5. 

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

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That Keep 

Records But Do Not 

Submit Reports

(E)

Total Annual 

Responses

E=(BxC)+D

1) Notification of initial performance test 1 2 0 2

2) Notification of initial CMS Demonstration 1 1 0 1

3) Report of initial performance test 1 2 0 2

4) Report of initial CMS demonstration NA 0

5) Report prior to construction (includes 

siting analysis) 1 1 0 1

6) Report prior to initial start-up 0.33 1 0 0.33

7) Report of initial stack test NA 0

8) Report established values for site-specific 

operating parameters 1 1 0 1

9) Waste management plan 1 1 0 1

10) Annual Report 4 1 0 4

11) Status report for operators that are offsite for more than 2 weeks 0.4 2 0 0.8

12) Corrective action summary for operators 

that are off-site for more than 2 weeks 0.4 4 0 1.6

13) Semiannual report of 

emissions/parameter exceedances 0.4 2 0 0.8

Total 15.53

NA - Included in capital/startup costs

The number of Total Annual Responses is 16 (rounded).

The total annual labor costs are $101,383. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and 

Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 below in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 1,036 hours at a cost of $101,383. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for 

Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart 

CCCC) (Renewal).
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Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 65 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $350,476. The 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 351

labor hours at a cost of $15,817. See below Table 2: Average Annual EPA Burden and Cost –

NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, 

Subpart CCCC) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in the total estimated respondent burden compared with the ICR 

currently approved by OMB. This increase is due to a multitude of factors including an increase 

in the respondent universe since the last ICR period, an update to the labor rates, as well as 

corrections to errors in the burden estimates. The primary correction included revising the 

number of existing respondents subject to annual reporting and recordkeeping requirements.

There is also an increase in the total capital and O&M costs due to an increase in the 

number of respondents. In addition, this ICR corrects the number of respondents that have to 

maintain monitors, which also contributes to the increase in O&M costs. 

There is a decrease in the Agency burden and cost due to several corrections, primarily

associated with the frequency of observing initial stack tests and reviewing excess emission 

reports. 

6(g) Burden Statement

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

is estimated to average 65 hours per response. Burden means the total time, effort, or financial 

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

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

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

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

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

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

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

the information.

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

collection of information unless it displays a valid OMB Control Number. The OMB Control 
15

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-2013-0315. 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), WJC 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-2013-0315 and OMB Control Number 2060-0662 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units

(40 CFR Part 60, Subpart CCCC) (Renewal)

Burden Item

(A) 

Respondent 

Hours per 

Occurrence 

(B) 

Number of 

Occurrences 

Per Respondent 

Per Year

(C) 

Hours Per 

Respondent 

Per Year 

(A x B)

(D) 

Number of 

Respondents 

Per Year

(E) 

Technical 

Hours Per 

Year 

(C x D)

(F) 

Management 

Hours Per 

Year 

(E x 0.05)

(G) 

Clerical 

Hours 

Per Year 

(E x 0.1)

H

Total 

Labor 

Costs Per 

Year a

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements b 1 1 1 1 1 0.05 0.1 $112.49

B. Required Activities

1) Initial stack test and report (PM, 

dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, 

NOx, and SO2)

Incl. in 

Capital/Startup

2) Annual stack test and test report (PM, HCl, 

Opacity, and Fugitive Ash)c

Incl. in O&M

3) Operator training and qualification 

a) Establish and teach operator qualification 

course b

64 1 64 1 64 3.2 6.4 $7,199.36

b) Obtain operator qualification b 72 1 72 1 72 3.6 7.2 $8,099.28

c) Annual refresher course c 12 1 12 4 48 2.4 4.8 $5,399.52

d) Initial review of site-specific information Incl. in 3A

e) Annual review of site-specific information c

8 1 8 4 32 1.6 3.2 $3,599.68

4) Establish operating parameters (maximum and 

minimum)b 40 1 40 1 40 2 4 $4,499.60

5) Continuous parameter monitoring (including 

CEMS) 

a) Initial monitoring 17 1 17 1 17 0.85 1.7 $1,912.33

b) Annual monitoring 17 1 17 4 68 3.4 6.8 $7,649.32

C. Create Information Incl. in 3B

D. Gather Information Incl. in 3E

E. Report Preparation

1) Notification of initial performance test c
17

Burden Item

(A) 

Respondent 

Hours per 

Occurrence 

(B) 

Number of 

Occurrences 

Per Respondent 

Per Year

(C) 

Hours Per 

Respondent 

Per Year 

(A x B)

(D) 

Number of 

Respondents 

Per Year

(E) 

Technical 

Hours Per 

Year 

(C x D)

(F) 

Management 

Hours Per 

Year 

(E x 0.05)

(G) 

Clerical 

Hours 

Per Year 

(E x 0.1)

H

Total 

Labor 

Costs Per 

Year a

a) Pollutants, fugitive ash emissions 2 1 2 1 2 0.1 0.2 $224.98

b) Fugitive Ash Emissions 1 1 1 1 1 0.05 0.1 $112.49

2) Notification of initial CMS Demonstration b 2 1 2 1 2 0.1 0.2 $224.98

3) Report of initial performance test c

a) Pollutants, fugitive ash emissions 8 1 8 1 8 0.4 0.8 $899.92

b) Fugitive Ash Emissions 2 1 2 1 2 0.1 0.2 $224.98

4) Report of initial CMS demonstration

Incl. in 

Capital/Startup

5) Report prior to construction (includes siting 

analysis) b

160 1 160 1 160 8 16 $17,998.40

6) Report prior to initial start-up

a) Without site specific parameter petition 6 1 6 0 0 0 0 $0

b) With site specific parameter petition f 14 1 14 0.33 4.67 0.23 0.47 $524.95

7) Report of initial stack test Incl. in 3B(1)

8) Report established values for site-specific 

operating parameters Incl. in 3B

9) Waste management plan b 160 1 160 1 160 8 16 $17,998.40

10) Annual Report:

a) Results of performance tests conducted during 

the year c 40 1 40 4 160 8 16 $17,998.40

11) Status report for operators that are off-site for 

more than 2 weeks d 8 2 16 0.4 6.4 0.32 0.64 $719.94

12) Corrective action summary for operators that 

are off-site for more than 2 weeks d 8 4 32 0.4 12.8 0.64 1.28 $1,439.87

13) Semiannual report of emissions/parameter 

exceedances e 24 2 48 0.4 19.2 0.96 1.92 $2,159.81

Subtotal for Reporting Requirements 1,012.08 $98,998.70

4. Recordkeeping Requirements

A. Read Instructions Incl. in 3A

B. Plan Activities N/A
18

Burden Item

(A) 

Respondent 

Hours per 

Occurrence 

(B) 

Number of 

Occurrences 

Per Respondent 

Per Year

(C) 

Hours Per 

Respondent 

Per Year 

(A x B)

(D) 

Number of 

Respondents 

Per Year

(E) 

Technical 

Hours Per 

Year 

(C x D)

(F) 

Management 

Hours Per 

Year 

(E x 0.05)

(G) 

Clerical 

Hours 

Per Year 

(E x 0.1)

H

Total 

Labor 

Costs Per 

Year a

C. Implement Activities N/A

D. Develop Record System N/A

E. Record Information

1) Records of operating parameters Incl. in 3B(5b)

2) Records of periods for which minimum amount 

of data on operating parameters were not obtained 0.5 52 26 0 0 0 0 $0

3) Records of malfunction of the unit 1.5 1 1.5 0 0 0 0 $0

4) Records of exceedances of the operating 

parameters e 1.5 2 3 0.4 1.2 0.06 0.12 $134.99

5) Records of stack tests Included in 3E

6) Records of siting analysis Included in 3E

7) Records of persons who have reviewed 

operating procedures b, c 1 1 1 4 4 0.2 0.4 $449.96

8) Records of persons who have completed 

operator training b, c 1 1 1 4 4 0.2 0.4 $449.96

9) Records of persons who meet operator 

qualification criteria b, c 1 1 1 4 4 0.2 0.4 $449.96

10) Records of monitoring device calibration Included in 3B

11) Records of site-specific documentation f 24 1 24 0.33 8 0.4 0.8 $899.92

F. Personnel Training Included in 3B

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 24.38 $2,384.79

TOTAL LABOR BURDEN AND COST (rounded) 1,036 $101,383

Assumptions:

(a) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “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.

(b)One-time only costs (1 new respondent per year).

(c) This ICR assumes the average number of respondents incurring costs during the 3 year period is 4.
19

(d) Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assumed that this 

required only two corrective action summaries.

(e) Assumed that 10 percent of the facilities would have an exceedance during the year. 

(f)Assumed that one-third of the facilities will petition for site-specific parameters.
20

Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI)

 Units (40 CFR Part 60, Subpart CCCC) (Renewal)

Burden Item

(A) 

EPA Hours 

per 

Occurrence

(B) 

Number of 

Occurrences 

Per 

Respondent 

Per Year

(C) 

EPA Hours 

Per 

Respondent 

Per Year 

(C=A x B)

(D) 

Number of 

Respondents 

Per Year

(E) 

Technical 

Hours Per 

Year

(CXD)

(F) 

Management 

Hours Per 

Year 

(E x 0.05)

(G) 

Clerical 

Hours Per 

Year 

(E x 0.1)

(H) 

Total 

Costs, $

1. Applications N/A

2. Read and Understand Rule Requirements b16 1 16 0 0 0 0 $0

3. Required Activities

A. Observe initial stack tests (PM, dioxins/furans, opacity, 

HCl, Cd, Pb, Hg, CO, NOx, and SO2)a 48 1 48 0.2 9.6 0.48 0.96 $497.52

B. Excess emissions -- Enforcement Activities c24 1 24 0.1 2.4 0.12 0.24 $124.38

C. Create Information N/A

D. Gather Information N/A

E. Report Reviews

1) Review waste management plan and siting analysis b8 1 8 1 8 0.4 0.8 $414.60

2) Review report submitted prior to initial startup b2 1 2 1 2 0.1 0.2 $103.65

3) Review initial stack test report b40 1 40 1 40 2 4 $2,072.98

4) Review annual compliance report d8 1 8 4 32 1.6 3.2 $1,658.38

5) Review semi-annual excess emission and parameter 

exceedance report c, d 16 1 16 0.4 6.4 0.32 0.64 $331.68

6) Review status reports and corrective action summary 

for operators off-site e 4 3 12 0.4 4.8 0.24 0.48 $248.76

F. Prepare annual summary report 200 1 200 1 200 10 20 $10,364.90

TOTAL ANNUAL BURDEN AND COST (rounded) 351 $15,817

Assumptions:

a. Assumes EPA personnel attend 20 percent of the stack tests 

b. One-time only costs.

c. Assume that 10 percent of the facilities have an exceedance during the year.

d. Assumes annual costs are not incurred until the second year of operation. For this ICR, assumes the average number of respondents incurring costs during the 3 

year period is 4 (see "Miscellaneous").
21

e. Assumed that 10 percent of the facilities would not have a qualified operator for more than two weeks at least once a year. Assumed that 1 status report and 2 

corrective action summaries are submitted.