### 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 Informati on Collection Emissions Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD) (Renewal) , EPA I CR 1927.05; OMB Control Number 2060

- 0451 1(b) Short Characterization/Abstract The Emission Guidelines for C ommercial and Industrial Solid Waste Incineration (CI SWI ) Units were promulgated on December 1, 2000. The guidelines (standards) appl y to solid waste incinerators in 40 CFR part 60, subpart DDDD. These standards fulfill the requirements of sections 111 and 129 of the Clean Air Act (CAA). This subpart affects the administrator of an air quality program in a state, or United States protectorate with one or more existing CI SWIunits that commenced construction on or before November 30, 1999. The emissions guidelines require: a one

- time waste management plan; initial performance tests for ten pollutants; annual performance testing for particulate matter (PM), hydrogen chloride (HCl), and opacity ; continuous operating parameter monitoring; annual operator tr aining; and annual reporting. A semiannual deviation report is required if any of the emission limitations or operating limits are exceeded. The frequency of these activities was chosen b y the United States Environmental Protection Agency (EPA) as the pe riod that will provide an adequate margin of assurance that affected facilities will not operate for extended periods in violation of the standards. This supporting statement addresses information collection activities imposed by the Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CI SWI ) Units, subpart DDDD. The guidelines do not apply directly to CI SWIunit owners and operators. The guidelines are implemented through the State Implementation Plans (SIP), written by the state s. If a state does not develop, adopt, and submit an approved state plan, and 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. The information w ill be used by enforcement and compliance authorities to ensure that the requirements of the state, or Federal plans are implemented and the subject facilities comply with the plans on a continuous basis. Specificall y, the information will be used by the authorities to: ( 1) identify

existing sources subject to the standards; ( 2) ensure those existing sources have a control plan to achieve compliance b y the final compliance date; ( 3) ensure that subpart DDDD is being properl y applied; ( 4) ensure that the em ission standards are being complied with; and ( 5) ensure, on a continuous basis, that the operating parameters established during the initial

### 2

stack test are not exceeded. In addition, records and reports are necessary to enable the authorities to id entify CISWI units that are not in compliance with the standards. Based on reported information, the designated administrator can decide which CISWI units should be inspected and what records or processes should be inspected at the CISWI unit. The record s that CI SWIunits maintain would indicate to the Administrator whether personnel are operating and maintaining the control equipment properl y and whether they have met the qualification requirements. In more than 95 percent of the cases, the enforcement of emission guidelines has been delegated to the state air pollution control agencies. In such cases, the reports required b y the standards will be submitted to the appropriate state agency , and not directly to the EPA. Thus, there is a minimal possibili ty for the duplication of information to state agencies and EPA. In those few cases where state agencies have not developed a state plan or requested delegation of the Federal plan, Federal enforcement requires information from the CI SWIfacilit y. The pl ant owner, or operator may submit a copy

of state, or local reports to the EPA Administrator in lieu of the report required by the standards, as specified in the General Provisions of 40 CFR part 60. This rule requires all records to be maintained at the source for a period of five years. These records must be kept on file for use of the regulating authority to ensure that the plant personnel are operating and maintaining control equipment properl y. There are approximately

97 respondents that will be s ubject to the standard in the next three ye ars. The previous Information Collection Request (ICR) assumed that the facilities regulated under the Emission Guidelines are owned by “business or other for

- profit,” Federal, and “State, Local; or Tribal Government.” Recent data indicate that the ownership is limited to the private industry . The average annual labor cost of this I CR is $2,884,100. The Office of Management and Budget (OMB) approved the current ICR without any “Terms of Clearance.” The burde n 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 Unit s (40 CFR Part 60, Subpart DDDD) (Renewal)

. The burden to the “Federal government” is attributed entirel y to work performed b y federal employees or government contractors; this burden may

be found below in Table 2: Average Annual EPA Burden

- Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 6 0, 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 proc edure similar to that provided by

section 110 under which each State shall

### 3 submit to the Administrator a plan which (A) establishes standards of performance for an y existing source for an y air pollutant (i) for which air qualit y criteria have not been issu ed 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 othe r 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 qualit y 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 gui delines 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 an y restricti on 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 mon itoring, recordkeeping, and reporting provisions consistent with the emission guidelines. In addition, section 114(a)(1)

### 4

states that: the Administrator may require any

person who owns or operates any emission source, who manufactures emission control equ ipment or process equipment, who the Administrator believes may have information necessary for the purposes set forth in this subsection, or who is subject to an y 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 m ethods; (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 reasonabl y require;
. . . . C ertain reports are necessary to enable the regulatory

agencies to identify

existing sources subject to the state plan that implements the emission guidelines and to determine if the standards are being achieved. Therefore, the emission guidelines were pro mulgated for this source category

at 40 CFR part 60, subpart DDDD. 2(b) Practical Utility/Users of the Data The information will be used by EPA, state, or local enforcement personnel to ensure that the requirements of the state or Federal plan are bei ng implemented and the subject facilities comply with the requirements of the plans on a continuous basis. Specifically , the information will be used to: ( 1) identify existing sources subject to the standards; ( 2) ensure that those existing sources have a control plan to achieve compliance by the final compliance date; ( 3) ensure that subpart DDDD is being properly applied; ( 4) ensure that the emission standards are being complied with; and ( 5) ensure, on a continuous basis, that the operating par ameters established during the initial performance test are not exceeded. In addition, records and reports are necessary to enable the authorities to identify CISWI units that may

not be in compliance with the standards. Based on reported information, the authorities can decide which CI SWIunits should be inspected and what records or processes should be inspected at the CI SWIunit. The records that CI SWIunits maintain would indicate to

### 5

the authorities whether the personnel are operating and maintainin g control equipment properl y and whether they

have met the qualification requirements.
3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 60, subpart DDDD. 3(a) N on - 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 to the delegated state, or local agency . If a state, or local agency has adopte d its own similar standards to implement the Federal standards, a cop y of the report submitted to the state, or a local agency can be sent to the Administrator in lieu of the report requirement by the Federal standards. Therefore, no duplication exists. 3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register on July 30, 2009 (74 FR 38004). No comments were received on the burden published i n the Federal Register

. 3(c) Consultations The primary

source of information was the industry and EPA data including an assessment by

the Office of Air and Radiation. Information provided by the industry

is retained in the EPA Air Facility

Sy stem (AFS ) database, which is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of all compliance data. Approximately 97 respondents are currentl y subject to the regulation. The Agency estimates that there will not be any industry growth in the next three years. It should be noted that the industry trade associations and other interested parties were provided an opportunit y to comment on the burden associated with the standard when it was proposed, and the standard was previousl y reviewed to determine the minimum information needed for compliance purposes. No major problems regarding the rule monitoring, recordkeeping, or reporting were identified during the public comment period.
In addition, it is our policy to review any

comments received since the last ICR renewal including those submitted in response to the First Federal Register Notice and respond appropriatel y. No comments were received for this I CR. 3(d) Effects of Less Fre quent Collection Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and

### 6

recordkeeping are useful techniques to ensure that good operati on and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected on a less frequent basis, the likelihood of detecting poor operation and maintenance of control equipment and noncompli ance would decrease. 3(e) General Guidelines None of these reporting or recordkeeping requirements violates an y of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require affected facilities to maintain all rec ords, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

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

- ye ar statute of limitations on which the permit program is based. Also, the retention of records for five ye ars would allow EPA to establish the compliance history

of a source and an y pattern of compliance for purposes of determining the appropriate level of enforcement action. Historically , EPA has found that the most flagrant violators frequentl y have violations extending beyond the five years. EPA would be prevented from pursuing the worst violators due to the destruction or nonexistence of records if records were retained for less than five years. 3(f) Confidentiality The required information has been determined not to be confidential. However, 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, Septemb er 20, 1978; 44 FR 17674, March 23, 1979). 3(g) Sensitive Questions None of the reporting, or recordkeeping requirements contains sensitive questions. 4. The Respondents and the Information Requested 4(a) Respondents/SIC and NAICS Codes The res pondents to the recordkeeping and reporting requirements are commercial and industrial solid waste incineration (CI SWI ) units. The United States Standard Industrial Classification (SI C) codes which correspond to the North American Industry Classification Sy stem (NAI CS) codes could be found in the following table :

### 7 Standard SIC Codes NAICS Codes Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR, part 60, subpart DDDD) Manufacturers of chemicals and allied produc ts 28 325 Manufacturers of electronic equipment 34 325 Manufacturers of wholesale trade, durable goods 36 421 Manufacturers of lumber and wood furniture 24 321 Manufacturers of wholesale trade, durable goods 25 337 Law enforcement agencies 9229 922 D epartment of Defense (labs, military bases, munition facilities) 9711 928

Research centers 8221 6113 4(b) Information Requested (i) Data Items All data in this I CR that are recorded and/or reported are required b y the Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR part 60, subpart DDDD). A source must make the following reports:

Notification Reports Standard Citation by Section Notification of final control plan 60.2600(a) Notification of fina l compliance 60.2605 Submit waste management plan 60.2755 Notification of initial and subsequent performance tests 60.2760 Notification of closure 60.2615 Annual report 60.2765 and 60.2770 Emission limitation or operating limit deviation report 60.27 75, and 60.2780 Qualified operator deviation notification 60.2785(a)(1)

### 8

Notification Reports Standard Citation by Section Status Report for operators that are off

- site more than two weeks 60.2785(a)(2) Notification of resumed operation 60.2785(b) Notification until increment is met 60.2595
A source must keep the following records: Recordkeeping Records of initial performance tests, annual performance tests, and an y subsequent performance tests. 60.2740(f)
Maintain records of day s for which data on operating parameters have been obtained. Includes a list of operating parameters not measured, reason for not measuring, and a description of corrective actions taken. 60.2740(c)

Maintain records of occurrence and duration of any malfunction and the corrective action taken. 60.2740(d)

Maintain records of day s when deviation from operating limits has occurred, and description of corrective actions taken. 60.2740(e)
Maintain records of names of persons who have completed review of site

specific information and incinerator operating procedures. 60.2740(g) and 60.2660(c) Maintain records of names of persons who have completed the operator training requirements. 60.2740(h)
Maintain records of phone and/or pager numbers of persons who have met the operator qualification criteria. 60.2740(i)

Maintain record s of calibration of monitoring devices. 60.2740(j) Maintain records of equipment vendor specifications for the incinerator, emission controls, and monitoring equipment. 60.2740(k)

Maintain records of dail y log of quantity and t ypes of waste burned. 60.27 40(m) Maintain records of site

- specific information and incinerator operation procedures. 60.2660(c)
Maintain records of operating parameters. 60.2740(b) Maintain calendar date of each record. 60.2740(a) Retain records for five ye ars. 60.2740

### 9

Electron ic Reporting Currently , sources are using monitoring equipment that provides parameter data in an automated way

(e.g., leaks and spills of mercury). Personnel at the source will still need to evaluate the data. This type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. In addition, some regulatory agencies are setting up electronic reporting sy stems to allow sources to report electronicall y which reduces the reporting burden. However, electroni c reporting sy stems are still not widely used b y the regulatory

agencies. Itis estimated that approximately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities Read instructions. Install, calibr ate, maintain, and operate control devices for, PM, HCl, and opacity

. Perform initial and annual performance tests. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developin g, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.
5. The Inform ation Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information.

### 10

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

. Audit facility

records. Input, anal yz e, and maintain data in the Air Facility Sy stem. Observe c ompliance tests (optional) 5(b) Collection Methodology and Management Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y installed and operated. Perform ance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard, and the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and publ ished for use in compliance and enforcement programs.
In formation contained in the reports is entered into the AFS, which is operated and maintained by

the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for more than 125,000 industrial and government

- owned facilities. EPA uses the AFS 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 b y this regulation must be retained by the owner or operator for five ye ars. 5(c) Small Entity Flexibility An exact number of small entities affected b y this rule could not be determined based on review of available documentation. According to the Final Rule (68 FR 57517):

During the 2000 CI SWIemission guidelines rulemaking, the EPA determined that based on the low number of affec ted small entities in each individual market, the alternative method of waste disposal available, and the relatively low control cost, the CI SWIemission guidelines should not generate a significant small business impact on a substantial number of small entities in the commercial and industrial sectors. A majority

of the a ffected facilities are large entities (e.g., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the

### 11

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. The Agency considers these requirements the minimum 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 several provisions that reduce the impact of the rule on all regulated entities which includes small entities. These are: 1..Annual performance testing is only required for three pollutants rather than the full ten pollutants included in the initial performance tests. 2..Operating parameter monitoring is required instead of continuous emissions monitoring sy stems (CEMS). 3..The owner or operator is allowed to skip two annual performance tests for a pollutant if all performance tests over the previous three ye ars show compliance. 4, Deviation reports are 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

- Emissions 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 i ndividual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of a burden und er 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 b e 31,619 hours (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the Emissions Guidelines program, the

### 12

previously

approved IC R, and an y comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates: $100.99 per hour for Executive, Administrative, and Managerial labor, $87.97 per hour for Technical labor, and $43.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2005, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates have been increased b y 110 percent to account for the benefit packages available to those employed b y private industry

.

Managerial $100.99 ($48.09 + 110%) Technical $87.97 ($41.89 + 110%) Clerical $43.81 ($20.86 + 110%) (ii) Estimating Capital/Startup and Operation and Maintenance Cos ts The ty pes of industry

cost associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the cost associated with continuous monitoring. The capital/startup costs are one - time cost when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs, such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Mainte nance (O&M) Costs
(A) Capital/Startup Cost for One Respondent 1 (B)

Number of Initial Respondents 2 (C)

Total Capital/Startup Cost (A x B) (D)

Annual O&M Costs for One Respondent3 (E)

Number of Respondents with O&M 2 (F)

Total O&M, (E x F) (G)

Total (C + F)

$2,240 0 $0 $211 97 $20,467 $20,467 1 The capital/startup costs and O&M could be found in Table 1 under column “Non

labor costs per occurrence per respondent” and “Total non

- labor costs per year”. Section 3B(1e) and (2d). 2 See Section 6(d) fo r calculation.

3 We assume that the annual O&M cost are $211 per year. 

### The total capital/startup costs for this I CR are zero. This is the total of column C in the above table. The total operation and maintenance (O&M) costs for this ICR are $20,467. This is the total of column F. The total respondent costs have been calculated as the addition of the capital/startup costs, and the annual operation and maintenance costs. The average annual cost for capital/startup and operation and maintenance cost to industry over the next three years of this I CR is estimated to be $20,467.

### 13

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. The EPA 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 ye ars of the ICR is estimated to be $ 46,463 (rounded)

. This cost is based on the average hourly labor rate at a GS

- 12, Step 1, times 1.6 benefits multiplication factor to account for government overhead expenses. The rates are as follows: Managerial $57. 20 (GS

- 13, Step 5, $35.75 x 1.6)

Technical $42.45 (GS

- 12, Step 1, $26.53 x 1.6) Clerical $22.96 (GS

- 6, Step 3, $114.35 x 1.6) These rates are from the Office of Personnel Management (OPM) “2006 General Schedule” which excludes locality

rates of pay. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden

- Emissions 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 As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 97. Number of Respondents

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of Initial Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (D)

Number of Existing Respondents with Initial Requirements (E) Number of Respondents (E=A+B+C

- D)
Average 0 97 0 0 9 7 

### The total number of annual responses per ye ar is calculated using the following table:

### 14
Total Annual Responses (A) Number of Initial Respondents (B)

Number of Reports for Initial Respondents (C)

Number of Existing Respondents (D)

Number of Rep orts for Existing Respondents (F)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(AxB)+(CxD)

0 0 97 1.4 1 0 136 (Rounded) 1 Each existing respondent submits an annual report. 10 percent submit an o perator status notification of resumed operation. 10 percent submit status report for operators that are off

- site for more than two weeks. 10 percent submit a corrective action summary report. 10 percent submit a semiannual exceedance report. Total num ber of reports per respondent is 1.4 per year. 

### The number of Total Annual Responses from the 97 respondents is 136. The Total Hours Requested is 31,619. The total annual labor costs are $ 2,884,100 . Details of the labor cost estimates may

be found belo w 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)

. Note that the total annual capital and O&M costs to the regulated entity are $20 ,467. These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. 6(e) Bottom Line Burden Hours Burden Hours and Cost Tables The bottom line burden hours and cost tables for both the Agency and the respon dents are attached. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 232 hours per response. 6(f) Reasons for Change in Burden There is no change in the cost to the respondents in this I CR compared to the previous ICR. This is due to two considerations: ( 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years; and ( 2) the growth rate for the respondents is very

low, negative or non - existent. Therefore, the cost figures in the previous ICR reflect the current burden to the respondents and are reiterated in this ICR. There is, however, a decrease of one hour in the total labor hours to the respondent in this I CR due to roundi ng. In accordance with the Paperwork Reduction Act, actions related to case development activities have been removed from the Agency cost figures. Therefore, the cost to the Agency as reported in this I CR has been reduced.

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6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 232 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or discl ose 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 information, processing an d maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2009

- 0542. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the sy st em , 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 Avenue, N.W., Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephon e 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, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please inc lude the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0542 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.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 I tems (A)

Respondent Hours per Occurrence (Technical hours) (B)

Number of Occurrenc es P er Responde nt Per Year (C) Hours Per Responde nt Per Year (C = A x B) (D) Number of Respondent s Per Year (E)

Technical Hours Per Year @$87.97 (C x D) b (F)

Managemen t Hours Per Year @$100.99 (E x 0.05) b (G)

Clerical Hours Per Year @$43.81 (E x 0.1) b (H)

Total Labor Costs Per Year b (I)

Emission Testing Contractor Hours Per Occurrence per Respondent (J)

Emission Testing Contractor Hours Per Year (D x I) (K)

Non

- Labor Costs Per Occurrence per Respondent Total Contractor/

Non

- Labor Costs Per Year (D x K) + (J x $100) k

1. APPLICATIONS N/A 2. SURVEY AND STUDIES N/A 3. REPORTI

NG REQUIREMENTS New Sources A. Read I

nstructions c&d 16 1 16 0 0 0 0 $0 0 0 $0 $0 B. Required Activities 1) I nitial re quirements a, c a) I nitial stack test (PM, dioxins/furans, opacity, HCl, Pb, Hg, SO 2 ) b) Establish and teach operator qualification course c) Obtain operator qualification d) Establish operating parameters (maximum and m inimum) e) Continuous parameter monitoring (including by

- pass stack) initial costs 16 64 72 160
9 e 1

1
1 1
1 16

64 72 160 9 0 a

0 a
0 a 0 a
0 a 0

0 0 0 0 0

0 0 0 0 0

0 0 0 0 $0

$0 $0 $0 $0 0 0 0 Included in 3B(a) 0 0

0 0 0 0 $0

$0 $0 $0 $0 $0

$0 $0 $0 $0

2) Periodic requirements a) Annual stack test and test report (PM, HCl, and Opacity) b) Annual refresher operator training course c) Annual review of site

- specific information d) Continuous parameter monitoring (including by

- pass stack) annual costs 12
12 8 83 1

1
1
1 12

12 8 83 97 g

97 g 97 g 97 g 1,164

1,164 776 8,051 58.2

58.2 38.8 402.55 116.4

116.4 77.6 805.1 $113,374.18

$113,374.18 $75,582.79 $784 ,171.42 125

0 0 0 12,125

0 0 0 $0

$0 $0 $211 h $1,212,500

$0 $0 $20,467

C. Create I

nformation Included in 3B D. Gather I

nformation Included in 3E E. Report Preparation

### 17

Burden I tems (A)

Respondent Hours per Occurrence (Technical hours) (B)

Number of Occurrenc es P er Responde nt Per Year (C) Hours Per Responde nt Per Year (C = A x B) (D) Number of Respondent s Per Year (E)

Technical Hours Per Year @$87.97 (C x D) b (F)

Managemen t Hours Per Year @$100.99 (E x 0.05) b (G)

Clerical Hours Per Year @$43.81 (E x 0.1) b (H)

Total Labor Costs Per Year b (I)

Emission Testing Contractor Hours Per Occurrence per Respondent (J)

Emission Testing Contractor Hours Per Year (D x I) (K)

Non

- Labor Costs Per Occurrence per Respondent Total Contractor/

Non

- Labor Costs Per Year (D x K) + (J x $100) k

1) Control plan 2) N otification of final compliance 3) Report of initial performance test 4) Siting analysis for new units only (established values for site

- specific operating parameters 5) Waste management plan 40 4 8 8

160 1

1 1 1

1 40

4 8 8

160 0

0 0 0

0 0

0 0 0

0 0

0 0 0

0 0

0 0 0

0 $0

$0 $0 $0

$0 0 0 50 0

0 0

0 0 0

0 $0

$0 $0 $0

$0 $0

$0 $0 $0

$0 6) Annual Report: g a) Site specific operating parameters 8 1 8 97 776 38.8 77.6 $75,582.79 0 0 $0 $0 b) Emiss ions/parameter exceedances and malfunctions Included in 3E 10 c) Results of stack tests conducted during the year Included in 3B d) Statement of no exceedances 8 1 8 97 776 38.8 77.6 $75,582.79 0 0 $0 $0 e) D oc umentation of use of by

pass stack Included in 6B f) Documentation for periods when all qualified operators were unavailable for more than 8 hours 8 1 8 97 776 38.8 77.6 $75,582.79 0 0 $0 $0
7) Status report for operator s that are off

- site for more than 2 weeks i 8 1 8 10 80 4 8 $7,792.04 0 0 $0 $0
8) Corrective action summary for operator that are off

- site for more than 2 weeks i 8 2 16 10 160 8 16 $15,584.08 0 0 $0 $0

9) Qualified operator deviation notific ation of resumed operation 8 1 8 10 80 4 8 $7,792.04 0 0 $0 $0 10) Semiannual report of emissions/parameter exceedances j 24 1 24 10 240 12 24 $23,376.12 0 0 $0 $0
Subtotal Reporting 16,149 $1,367,795 12,125 $1,232,967 4. Record

keeping Requirements A. Read I

nstructions Included in 3A B. Plan Activities Included in 3B C. I mplement Activities Included in 3B D. Develop Record System N/A

### 18

Burden I tems (A)

Respondent Hours per Occurrence (Technical hours) (B)

Number of Occurrenc es P er Responde nt Per Year (C) Hours Per Responde nt Per Year (C = A x B) (D) Number of Respondent s Per Year (E)

Technical Hours Per Year @$87.97 (C x D) b (F)

Managemen t Hours Per Year @$100.99 (E x 0.05) b (G)

Clerical Hours Per Year @$43.81 (E x 0.1) b (H)

Total Labor Costs Per Year b (I)

Emission Testing Contractor Hours Per Occurrence per Respondent (J)

Emission Testing Contractor Hours Per Year (D x I) (K)

Non

- Labor Costs Per Occurrence per Respondent Total Contractor/

Non

- Labor Costs Per Year (D x K) + (J x $100) k

E. Record I

nformation 1) Records of operating parameters Included in 3B 2) Records of periods for which minimum amount of data on operating parameters were not obtained 0.5 52 26 10 260 13 26 $25,324.13 0 0 $0 $0

3) Record s of malfunction of the unit 1.5 1 1.5 10 15 0.75 1.5 $1,461 0 0 $0 $0 4) Records of exceedances of the operating parameters 1.5 1 1.5 10 15 0.75 1.5 $1,461 0 0 $0 $0 5) Records of stack tests Included in 3E 6) Records of persons who have reviewed operating procedures 1 1 1 97 97 4.85 9.7 $9,447.85 0 0 $0 $0 7) Records of persons who have completed operator training 1 1 1 97 97 4.85 9.7 $9,447.85 0 0 $0 $0 8) Records of persons who meet operator qualification criteria 1 1 1 97 97 4.85 9.7 $9,447.85 0 0 $0 9) Records of monitoring device calibration Included in 3B 10) Records of site

- specific documentation 24 1 24 97 2,.328 116.4 232.8 $226,748.36 0 0 $0 $0
F. Personnel Training Included in 3B G. Time for Audits N/A Subtotal Recordk

eeping 3,345 $283,338 0 $0 TOTAL 19,494 $1,651,133 12,125 $1,232,967 Labor Hours Contractor Labor Hours Total Hours Labor Cost Contractor / Non

Labor Cost Total Cost

e Summary of Respondent Burden Annual Capital/Startup Costs O & M Summary 19,494 12,125 31,619 $1,651,133 .28 $1,232,96

7 $0 $20,467 $2,884,100

$20,467

Assunptions: a. The average number of respondents per year over the three

- year period of the renewal is 97. b. We assume that all tasks are to be performed by managerial, technical and clerical personnel. This ICR uses the followin g labor rates: $100.99 for Managerial labor, $87.97 for Technical

### 19

labor and $43.81 for Cleri cal labor. These rates are from the United States Department of Labor Bureau of Labor Statistics, December 2005, “Table 2. C ivilian Workers, by occupational and industry group. The rates have been increased by 110 percent to account for the benefit packa ges available to those employed by private industry. We also included contractors at $100. The labor rate was also taken from the above occupational and industry group under Blue

- Collar occupation that covers Machine operators, and took the rates from co lumn 1, “Total compensation.” c. This activity is based on a one

- time cost only. d. Cost 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 In cinerators (MWI s)

- Methodology and Assumptions (A

- 91

- 61,I V

- B

- 66), the assumption is that ($300 will be for planning + $500 for selection)/$89.94 per hour = 9 hours. f. Total capital cost of parameter monitoring for wet scrubbers minus costs for plannin g and selecting equipment 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 with a 1.06 cost adjustment = $2,240. g. Respondents make one combined annual report per year. h. Based on memorandum titled "Revised Testing and Monitoring Options and Costs for Medical Waste I ncinerators (MWI s)

- Methodology and Assumptions [A

- 91

- 61, I V

- B

- 66], the respondents spend 83 hours for reporting; operation and maintenance cost s - $1,693 x 0.11746 = $199; $199 x 1.06 cost adjustment = $211. i. Assume that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assume that this required only two corrective action summaries. j. Assume that 10 percent of the facilities would have an exceedance during the year. k. Assume that the average cost for contractor is $100.00 per hour.

### 20

TABLE 2: Average Annual EPA Burden
- Em ission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD)

BURDEN ITEMS (A) Hours Per Occurrences (B)

Number of Occurrence Per Year a (C)

Tech Hours Per Year @ $42.45 (C = A x B ) b (D)

Management Hours Per Year @ $57..20 (D = C x 0.05) b (E)

Clerical H ours Per Year @ $22.96 (E = C x 0.1) b (F)

Cost Per Year

1. Applications N/A 2. Read and Understand Rule Requirements 16 0 0 0 0 $0 3. Required Activities Report Reviews 1) Review control plan 8 0 0 0 0 $0 2) Review notifi cation of final compliance 8 0 0 0 0 $0 3) Review waste management plan 8 0 0 0 0 $0 4) Review initial stack test report 40 0 0 0 0 $0 5) Review annual compliance report 8 97 776 38.8 77.6 $36,942.22 6) Review semi

- annual excess emissio n and parameter exceedance report 16 10 160 8 16 $7,616.96 7) Review status reports and corrective action summary for operators off

- site 4 10 40 2 4 $1,904.24 TOTAL 1,122 (rounded) $4 6,463 (rounded) Assumptions: a. Costs are based on the fo llowing rates obtained from the Office of Personnel Management (OPM) “2006 General Schedule” which excludes locality rates of pay and multiplied by 1.6 to account for government overhead expenses: 1) Managerial at $57.20, 2) Technical at $42.45, and 3) Clerical at $22.96 per hour. These rates are increased by 1.6 benefits multiplication factor to account for government overhead expenses. b. We assume that 10 percent of the facilities will have exceedance reports and operator off

- site reports. c. We assum e that each state will prepare an annual summary of progress for implementing the state plan. One occurrence per year x 50 s tates = 50 occurrences. d. We assume that 10 percent of the compliance tests (annual or initial) are observed, and that it takes 4 8 hours each.