SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 

CFR Part 60, Subpart DDDD) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emissions Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR 

Part 60, Subpart DDDD) (Renewal), EPA ICR 1927.05; OMB Control Number 2060-0451

1(b) Short Characterization/Abstract

The Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units were promulgated on December 1, 2000. The guidelines (standards) apply 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 CISWI units 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 

training; 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 by the 

United States Environmental Protection Agency (EPA) as the period 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 (CISWI) Units, 

subpart DDDD. The guidelines do not apply directly to CISWI unit owners and operators. The 

guidelines are implemented through the State Implementation Plans (SIP), written by the states. 

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 will 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. Specifically, the information will be used by the authorities 

to: (1) identify existing sources subject to the standards; (2) ensure those existing sources have a 

control plan to achieve compliance by the final compliance date; (3) ensure that 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 parameters established during the initial 
2

stack test are not exceeded.

In addition, records and reports are necessary to enable the authorities to identify 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 records that CISWI units maintain would 

indicate to the Administrator whether personnel are operating and maintaining the control 

equipment properly 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 by the standards will be submitted 

to the appropriate state agency, and not directly to the EPA. Thus, there is a minimal possibility

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 CISWI facility. The plant 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 properly.

There are approximately 97 respondents that will be subject to the standard in the next 

three years. 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 ICR is $2,884,100.

The Office of Management and Budget (OMB) approved the current ICR without any

“Terms of Clearance.”

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent 

Burden and Cost - Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

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

attributed entirely to work performed by 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 60, Subpart DDDD) 

(Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 111(d)(1) of the Clean Air Act (CAA), as amended, to:

. . . prescribe regulations which shall establish a procedure similar 

to that provided by section 110 under which each State shall 
3

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 promulgated 

under section 111 and this section shall reflect the maximum 

degree of reduction in emissions of air pollutants listed under 

section (a)(4) that the Administrator, taking into consideration the 

cost of achieving such emission reduction, and any non-air quality 

health and environmental impacts and energy requirements, 

determines is achievable for new or existing units in each category.

Section 129(b)(1) states:

Performance standards under this section and section 111 for solid 

waste incineration units shall include guidelines promulgated 

pursuant to section 111(d) and this section applicable to existing 

units. Such guidelines shall include, as provided in this section, 

each of the elements required by subsection (a) (emissions 

limitations, notwithstanding any restriction in section 111(d) 

regarding issuance of such limitations), subsection (c) 

(monitoring), subsection (d) (operator training), subsection (e) 

(permits), and subsection (h)(4) (residual risk).

Subpart B of 40 CFR part 60 requires state plans to include monitoring, recordkeeping, 

and reporting provisions consistent with the emission guidelines. In addition, section 114(a)(1) 
4

states that:

the Administrator may require any person who owns or operates 

any emission source, who manufactures emission control 

equipment or process equipment, who the Administrator believes 

may have information necessary for the purposes set forth in this 

subsection, or who is subject to any requirement of this Act (other 

than a manufacturer subject to the provisions of section 206(c) or 

208 with respect to a provision of title II) on a one-time, periodic 

or continuous basis to:

(A) establish and maintain such records; (B) make 

such reports; (C) install, use, and maintain such 

monitoring equipment, and use such audit 

procedures, or methods; (D) sample such emissions 

(in accordance with such procedures or methods, at 

such locations, at such intervals, during such 

periods and in such manner as the Administer shall 

prescribe); (E) keep records on control equipment 

parameters, production variables or other indirect 

data when direct monitoring of emissions is 

impractical; (F) submit compliance certifications in 

accordance with section 114(a)(3); and (G) provide 

such other information, as the Administrator may

reasonably require; . . . .

Certain 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 promulgated 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 being 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 parameters 

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 CISWI units should be inspected and what records or processes 

should be inspected at the CISWI unit. The records that CISWI units maintain would indicate to 
5

the authorities whether the personnel are operating and maintaining control equipment properly 

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) 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 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 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 ICR was published 

in the Federal Register on July 30, 2009 (74 FR 38004). No comments were received on the 

burden published in 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 System (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 currently 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 opportunity to comment on the burden associated with the standard when it was 

proposed, and the standard was previously 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 

appropriately. No comments were received for this ICR.

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 
6

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 on a less frequent basis, the likelihood of detecting poor operation and maintenance of 

control equipment and noncompliance would decrease.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violates any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5.

These standards require affected facilities to maintain all records, including reports and 

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

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

the part 70 permit program and the five-year statute of limitations on which the permit program 

is based. Also, the retention of records for five years would allow EPA to establish the 

compliance history of a source and any pattern of compliance for purposes of determining the 

appropriate level of enforcement action. Historically, EPA has found that the most flagrant 

violators frequently 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 by 43 FR 40000, September 8, 1978; 43 FR 42251, September 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 respondents to the recordkeeping and reporting requirements are commercial and 

industrial solid waste incineration (CISWI) units. The United States Standard Industrial 

Classification (SIC) codes which correspond to the North American Industry Classification 

System (NAICS) 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 products 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

Department of Defense (labs, military bases, munition 

facilities)

9711 928

Research centers 8221 6113

4(b) Information Requested

(i) Data Items

All data in this ICR that are recorded and/or reported are required by 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 final 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 60.2775, 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 any 

subsequent performance tests.

60.2740(f)

Maintain records of days 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 days 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 sitespecific 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 records 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 daily log of quantity and types of waste burned. 60.2740(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 years. 60.2740
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Electronic 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 systems to allow sources to report electronically which reduces the 

reporting burden. However, electronic reporting systems are still not widely used by the 

regulatory agencies. 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 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 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.

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.
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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 Air Facility System.

Observe compliance 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 properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard, and the operating conditions under which compliance was achieved. 

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs.

Information contained in the reports is entered into 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 by this regulation must be retained by the owner or operator for five 

years.

5(c) Small Entity Flexibility

An exact number of small entities affected by this rule could not be determined based on 

review of available documentation. According to the Final Rule (68 FR 57517): 

During the 2000 CISWI emission guidelines rulemaking, the EPA 

determined that based on the low number of affected small entities 

in each individual market, the alternative method of waste disposal 

available, and the relatively low control cost, the CISWI emission 

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 affected 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 types 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 systems (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 years 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 individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

concept of a burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

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

collection of information unless it displays a currently valid OMB control number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 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 ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR 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 by 110 percent to account for the benefit packages available to those 

employed by 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 Costs

The types 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 Maintenance (O&M) Costs

(A)

Capital/Startup 

Cost for One 

Respondent1

(B)

Number of 

Initial 

Respondents2

(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 “Nonlabor costs per occurrence per respondent” and “Total non-labor costs per year”. Section 3B(1e) 

and (2d).

2 See Section 6(d) for calculation.

3

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

The total capital/startup costs for this ICR 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 ICR is estimated to be $20,467.
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6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis 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 years 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-year 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 97

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

(A)

Number of 

Initial 

Respondents

(B)

Number of 

Reports for 

Initial 

Respondents

(C) 

Number of 

Existing 

Respondents

(D) 

Number of 

Reports 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 1.410 136 (Rounded)

1 Each existing respondent submits an annual report. 10 percent submit an operator 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 

number 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 below in Table 1: Annual Respondent Burden and Cost - Emission 

Guidelines for Commercial and Industrial Solid Waste Incineration Units (40 CFR part 60, 

subpart DDDD) (Renewal).

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 respondents 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 ICR compared to the previous 

ICR. This is due to two considerations: (1) the regulations have not changed over the past three 

years 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 ICR due to 

rounding. 

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 ICR 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 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 

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-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 system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution 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 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, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include 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 Items

(A)

Respondent 

Hours per 

Occurrence 

(Technical 

hours)

(B)

Number of 

Occurrenc

es Per 

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. REPORTING REQUIREMENTS

New Sources

A. Read Instructions c&d 16 1 16 0 0 0 0 $0 0 0 $0 $0 

B. Required Activities

1) Initial requirements a, c

 a) Initial stack test (PM, 

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

SO2)

 b) Establish and teach operator 

qualification course 

 c) Obtain operator qualification

 d) Establish operating parameters 

(maximum and minimum) 

 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 

97g

97g

97g

97g

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 

$211h

$1,212,500

$0

$0

$20,467 

C. Create Information Included in 

3B

D. Gather Information Included in 

3E

E. Report Preparation
17

Burden Items

(A)

Respondent 

Hours per 

Occurrence 

(Technical 

hours)

(B)

Number of 

Occurrenc

es Per 

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) Notification 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) Emissions/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) Documentation of use of bypass stackIncluded 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 operators 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 

notification 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. Recordkeeping Requirements

A. Read Instructions Included in 

3A

B. Plan Activities Included in 

3B

C. Implement Activities Included in 

3B

D. Develop Record System N/A
18

Burden Items

(A)

Respondent 

Hours per 

Occurrence 

(Technical 

hours)

(B)

Number of 

Occurrenc

es Per 

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 Information 

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) Records 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 Recordkeeping 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

/NonLabor 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 following labor rates: $100.99 for Managerial labor, $87.97 for Technical 
19

labor and $43.81 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 by 110 percent to account for the benefit packages 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 column 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 Incinerators (MWIs) - Methodology and Assumptions (A-91-61,IV-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 planning 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 Incinerators (MWIs) - Methodology and Assumptions [A-91-61, IV-B-66], the 

respondents spend 83 hours for reporting; operation and maintenance costs - $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 - Emission 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 Hours 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 notification 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 emission 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) $46,463 (rounded)

Assumptions:

a. Costs are based on the following 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 assume that each state will prepare an annual summary of progress for implementing the state plan. One occurrence per year x 50 states = 50 occurrences.

d. We assume that 10 percent of the compliance tests (annual or initial) are observed, and that it takes 48 hours each.