**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60,**  **Subpart FFFF) (Renewal)**
**1. Identification of the Information Collection 1(a) Title of the Information**  **Collection** Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal) , EPA I CR Number 2164.0 4 , OPM Control Number 2060

- 0562 **1(b) Short Characterization/Abstract** Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF ) were proposed o n December 9, 2004 (69 FR 7147 1 ) , promulgated on December 16, 2005 (70 FR 74892) , and amended on November 24, 2006 (71 FR 67806)

. The regulated OSWI units include two subcate gories: very small municipal waste combustion (VSMWC) units that combust less that 35 tons per day of waste and institutional waste incineration (IWI ) units. This standard applies to an y air quality p rogram in a state or United States protectorate with one or more existing other solid waste incineration (OSWI) units or air curtain incinerators that commenced construction on or before December 9, 2004. T his subpart does not directly a ffect incineration unit owners and operators; however, they must compl y wi th the state’s plan that was developed b y the air quality

p rogram administrator to implement the emission guidelines. This information is being collected to assure compliance with 40 CFR part 60, subpart FFFF. In general, all New Source Performance Stan dards (NSPS) require initial notifications, performance tests, one - time and periodic reports. T hey 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 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 NSPS. Any owners or operators 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 office. Over the next three ye ars, an average of 99 respondents per ye ar will be subject to the standard, and no additional respondents will become subject to the standard

. T his standard applies to OSWIunits that commenced construction on or before December 9, 2004. T herefore, there will be no new units constructed during the period covered b y this I CR. The Office of Management and Budget (OMB) approved the currently active ICR withoutany

“Terms of Clearance.” All of the other solid waste incineration (OSWI) units in the United States , are owned and operated b y the solid waste incineration industry (the “Affected Public”). However, this ICR applies directl y to the emission guidelines with most of the units regulated by either, state, local, tribal or the Federal government. T hey are considered not

- for

- profit businesses. T he burden to the “Affected Public” is listed below in Table 1: Annual Respondent Burden and Cost

− Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF ) (Renewal)

. The Federal government burden associated with the review of reports submitted by the respondent is shown below in Table 2: Average Annual EPA Burden and Cost

– Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF ) (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 b y s ection 110 under which each State s hall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant (i) for which air quality criteria have not been issued or which is not included on a list published under section 108(a)
**. . .**  but (ii) to which a standard of performance under this section would apply if such existing source were a new source, and (B) provides for the implementation and enforcement of such standards of performance. The EPA is required under section 129 of the Act, to establish guidelines for existing stationary sources that reflect the maximum achievable control technology (MACT) for achieving continuous emission reductions: Section 129(a)(1)(A) states: The Administrator shall establish performance standards and other requirements pursuant to section 111 and this section for each 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 promulgatedunder section 111 and this section shall reflect the maximum degree of reduction in emissi ons 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 fo r 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 a pplicable 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), sub section (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 p erson who owns or operates any emission source, who manufactures emission control equipment or process equipment, who the Administrator believes may h ave information necessary

for the purposes set forth in this subsection, or who is subject to any requirement of this Act (other than a manufacturer subject to the provisions of section 206(c) or 208 with respect to a provision of title II) on a one

- time, periodic or continuous basis to

- (A) establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such pro cedures 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 em issions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3); and4 (G) provide such other information, as the Administrator may

reasonably

require;
**. . . .** In the Administrator's judgment, pollutant emissions from other solid waste incineration units cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the emission guidelines were promulgated for this source category at 40 CFR part 60, subpart FFFF. **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. T he collected information is used also for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility’s i nitial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y installed and operated, that leaks are being detected and repaired, and that the 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 FFFF. **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 directl y to the delegated state or local agency
. If a state or local agency h as adopted their 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 b y the Fed eral standards. Therefore, duplication does not exists.5

**3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R was published in the Federal Register ( 76 FR 26900 ) on May 9 , 2011 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations**
T he Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. 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 b y the EPA Office of Complianc e. OTIS is EPA ’s database for the collection, maintenance, and retrieval of all compliance data. T he growth rate for the industry i s based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interest ed parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. In developing this I CR , we contacted : 1) the National Solid Waste Management Association (NSWMA) , at (202) 364

- 3773 ; and 2) the Solid Waste Association of North America (SWANA) , at (240) 494

- 2253. EPA did not receive any comments from the consultations. It is our polic y t o respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. **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 emissio n limitations are met. If the information required b y these standards were collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General Guidelines**
T h ese reporting or recordkeeping requirements do not violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least fi ve years. T his is consistent with the General Provisions as applied to the standards. E PA believes that the five

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

- ye ar 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 p attern of non - compliance, and to determine the appropriate level of enforcement action. E PA6

has found that the most flagrant violators have violations extending beyond the 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 i nformation submitted to the Agency for which a claim of confidentiality i s 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Informat ion Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are other solid waste incineration units. The United States Standard Industrial Classification (SI C) codes for the respondents affected b y the standards, which correspond to the North American Industry Classification System (NAI CS) code s , are listed in the following table

. **Standard (40 CFR, part 60, subpart FFFF) SIC Codes**  **NAICS Codes**  Solid Waste Combustors and Incinerators 4953 562213 Administration of Air and Waste Resource and Solid Waste Management Programs 9511 924110 Nursing and Residential Care Facilities 8051, 8052, 8059, 8361 623 Justice, Public Order, and Safety Activities 9211, 9221, 9222,

9223, 9 224, 9229, 8322 922

Nation al Security and International Affairs 9711, 9721 928 Elementary

and Secondary

Schools 8211 611110 Junior Colleges 8222 611210 Colleges, Universities, and Professional Schools 8221 611310 Museums, Historical Sites, and Similar Institutions 8412, 8422, 7999 7121 Religious Organizations 8661 813110 Civic and Social Organizations 8641, 8699 8134107

**4(b) Information Requested (i) Data Items**  In this ICR, all the data recorded or reported is required by the Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF). A source must make the following reports:
**Notifications** Waste management plan 60.3010, 60.3011, 60.3012 Notification of operating limit deviation report 60.3052 and 60.3053 Notification of deviation 60.3054(a)(1) Notification of status report 60.3054(a)(2) Notification of resumed operation 60.3054(b) **Reports** Initial performance test and report 60.3049, 60.8(a) Annual compliance test report 60.3050 , 60.3053 Semiannual report of deviation 60.3052 A source must keep the following records: **Recordkeeping** Maintain records of all test reports 60.3068(a) Records are required to be retained for five years 60.3068(e) Maintain waste management plan records 60.3010
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

a gencies , in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are not widel y used. At this time, it is estimated that 10 per cent of the respondents use electronic reporting.8 **( ii) Respondent Activities** 

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate a coil coating line at their metal coil surface coating plants. Perform initial performance test, Reference Methods, 3A, 3B, 26A tests, and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and 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 infor

mation. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides 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 significantly reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Inf ormation**  **Management 5(a) Agency Activities** 
EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Inform ation Sy stem ( OTI S )

.9

**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 i nstalled and operational

. P erformance test reports are used b y 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.
In formation contained in the reports is entered into OTI S, which is operated and maintained by

the EPA Office of Compliance. OTI S is EPA ’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA us es 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. The records required b y th is regulation must be retained by the owner or operator for five ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) w as taken into consideration during the development of the regulation. 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. T he Agency c onsiders these 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

f or each information collection activity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

− Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (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 fo r the subpart included in this I CR. The 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 b een identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a10

collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimat ing Respondent Burden**  The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 70,132 (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 I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.27 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics , September 20 11 “Table 2 : Civilian Workers , by o ccupational and i ndustry group.” The rates are from column 1, “Total C ompensation.” 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 monitori ng. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs, such as photocopying and postage.

**(iii) Capita l/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)

Continuous emission mo nitoring system $44,445 0 $0 $5,000 99 $ 495,000

$0 $495,00011

The total capital/startup costs for this I CR are zero. This is the total of column D in the above table. The total operation and maintenance (O&M) costs are $ 495,000 . This is the total of column G.
The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the I CR is estimated to be $ 495,000

. **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 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 $ 389,912

. This cost is based on the average hourl y 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) , 20 11 General Schedule , which excludes locality rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to gover nment employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

− Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (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 99 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject to the standard. The average number of respondents, as shown in the table below, is 99 per ye ar. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.12 **Number of Respondents** 

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 99 0 0 99 2 0 99 0 0 99 3 0 99 0 0 99 Average 0 99 0 0 99

1 New respondents 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 99

. 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

Notification of final compliance 82.7 0 0 0 Initial compliance report 82.7 0 0 0 Waste management plan 82.7 0 0 0 Annual compliance reports 99 2 0 198 Semiannual deviation reports 99 1 0 99 Total 297 The number of Total Annual Responses is 297

. The total annual labor costs are $ 6 , 720 , 028 . Details regarding these estimates will be found below in Table 1: Annual Respondent Burden and Cost

− Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal)

. **6(e) Bottom Line Burden Hours Burden Hours and Cost Tables**
The detailed botto m line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 70,132 , at a cost of $6,720,028 . Details regarding these13

estimates may

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

− Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal )

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 236 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $ 495,000

. The co s t 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 8,653 labor hours , at a cost of $ 389,912

. See below Table 2 : Average Annual EPA Burden and Cost

− Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal )

. **6(f) Reasons for Change in Burden** There is a decrease in the total estimated burden for both the respondents and the Agency from the most recently

approved ICR due to a decrease in the number of sources. At the time of rule promulgation, EPA estimated that 248 respondents were subject to the standard. Howev er, many facilities have shut down or ceased operation since 2005

. In recent years in support of potential OSWIregulatory development, the Agency consulted with internal data experts and conducted data and permits searches to inventory the number of existing OSWIunits. The data collection activities in 2010 suggest that onl y 99 VSMWC and IWIsources are subject to the standard. This represents an approximately 60 percent decrease in the respondent universe since 2005. The decrease in the respondent universe also results in significant reduction of the overall O&M costs to the respondents. Additionally , this IC R corrects a mathematical error in the previous I CR’s estimate for the respondent recordkeeping burden

. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 236 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate , maintain, retain, 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 i nformation, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete14

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 ’ s 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 s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0256

. 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 content of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Do cket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., 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 holid ay s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 17 52

. Also, you can send comments to the Off ice of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2011

- 0256 and OMB Control Number 2060

- 05 62 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.**Table 1:**  **A nnual**  **Respondent Burden**  **and Cost** 

**– Emission**  **Guidelines for**  **Existing Other**  **Solid Waste**  **Incineration Units**  **(40**

**CFR Part 60, Subpart FFFF) (Renewal)** 

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per resp**  **ondent per year**  **(C)**

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions c 40 1 40 0 0 0 0 $0 B. Required activities 1) Initial performance test and reports a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) c, d 24 1 24 0 0 0 0 $0
b) Repeat of initial performance tests d, e 24 1 24 0 0 0 0 $0 2) CEMS demonstration (CO, 02) a) Repeat of initial demonstration e 229 1 229 0 0 0 0 $0 3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg) 24 1 24
99 2,376 118.8 237.6 $261,819.28 4) Quarterly Appendix F audits of CEMS (CO) a) RATA audit (one per year) f 4 1 4 99 396 19.8 39.6 $43,636.55 b) RAA audit (three per year) f 4 3 12 99 1,188 59.4 118.8 $130,909.64 c) Daily calibration and operation f, g 1 250 250 99 24,750 1,237.5 2,475 $2,727,284.18 C. Create information See 3B D. Gather information See 3E E. Report preparation 1) Contract or secure alternative means of disposal d 40 1 40 0 0 0 0 $0 2) Notification of final compliance c, d 1.5 1 1.5 0 0 0 0 $0 3) Initial compliance report c, d 40 1 40 0 0 0 0 $0 4) Waste management plan c, d 40 1 40 0 0 0 0 $0 5) Annual compliance reports 40 1 40 99 3,960 198 396 $436,365.4716

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per resp**  **ondent per year**  **(C)**

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

6) Semiannual deviation reports 24 2 48 99 4,752 237.6 475.2 $523,638.56 **Subtotal for Reporting Requirements 43,035**  **.3** 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 SSM h 1.5 52 78 99 7,722 386.1 772.2 $850,912.66 2) Records of emission rate computations, all emission exceedances and periods w hen there is no data h 1.5 52 78
99 7,722 386.1 772.2 $850,912.66 3) Records of employee review of operations manual 4 1 4 99 396 19.8 39.6 $43,636.55 4) Record of control devices operating parameters h 1.5 52 78 99 7,722 386.1 772.2 $850,912.66 F. Personnel training N/A G. Time for audits N/A **Subtotal for Recordkeeping Requirements 27**  **,0 96**  **.3 60,984**  **3,049.3 6,098.4**  **TOTAL LABOR BURDEN AND COST (rounded)**  **70,132 $**  **6,720,028**

**Assu mptions:**  a We have assumed that there are approximately 99 respondents, with no additional ne w o r reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 “ Ta ble 2 : Civilian Workers, by o ccupational and i ndustry group. ” The rates are from column 1, “ Total C om pensation. ” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. c We have assumed that this is a one

- time only cost. d This is the fifth year when a respondent will have reached the compliant date for the emission guidelines. e We have assumed that 20 percent of respondents will repeat initial tests due to failure.17

f We have assumed that RATA audits are performed for o ne of the four quarterly audits, and RAA tests are performed for three of the four quarterly audits. g We have assumed that each operation day requires a CEMS calibration; Combustor models 2, 3, and 4 assume 250 days of operatio n per year, Model 1 = 121 d ays/yr. For consistency, 250 operating days are assumed for all models. Emission testing hours (0.25 hr/occurrence) accounts for periodic contractor operation and maintenance support. Annual hours averaged to a daily basis. h We have assumed that each respondent will record information 52 times per year.18

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

**– Emission Guidelines**  **for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF)**  **(Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E) Technical**  **person**   ** hours per** **year (E=CxD)**  **(F)**

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

1. Applications N/A 2. Read and understand rule requirements 16 1 16 0 0 0 0 $0 3. Required activities A. Create information N/A B. Gather information See 3A & 3F C. Report review s 1) Notification of final compliance c 1.5 1 1.5 0 0 0 0 $0 2) Review

initial compliance test report c 40 1 40 0 0 0 0 $0 3) Review

annual compliance report 40 1 40 99 3,960 198 396 $205,216.70 4) Review

semiannual deviation reports 16 2 32 99 3,168 158.4 316.8 $164,173.36 5) Review waste management plan c 16 1 16 0 0 0 0 $0.00 D. Annual summary report d 4 1 4 99 396 19.8 39.6 $20,521.67 **TOTAL ANNUAL BURDEN AND COST**  **(rounded) 8,**  **653 $**  **389 ,9**  **12**

**Assu mptions:**  a We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. For the purpose of the burden calculation, we are averaging the num ber of r espondents over the three years period of this ICR. I n year two and three of this ICR all respondents will have reached the compliant date for the emission guidelines, which is five years after prom ulgation. b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government o verhead expenses: $ 62.27 for Managerial (GS

- 13, Step 5, $ 38.92 x 1.6), $ 46.21 for Technical (GS

- 12, Step 1, $ 28.88 x 1.6) and $ 25.01 Clerical (GS

- 6, Step 3, $ 15.63 x 1.6). T hese rates are from the Office of Personnel Management (OPM) , 20 11 General Schedule , which excludes locality rates of pay. c We have assumed that this is a one

- time only cost. d We have assumed that all affected facilities in the states will be required to prepare an annual summary plan. Designated Administrator refers to the person indicated by each State plan as the compliance authority or to the USEPA Admini strator in the event that a Federal p lan must be developed.