SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) 

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

CFR Part 60, Subpart DDDD) (Renewal), EPA ICR Number 2385.06, OMB Control Number 

2060-0664.

1(b) Short Characterization/Abstract

The Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units were proposed on April 29, 2010, promulgated on March 21, 2011 (76 FR 15769) 

and amended on February 7, 2013 (78 FR 9195). The Emission Guidelines revise the existing 

2000 rule, and do not apply directly to CISWI unit owners and operators. The guidelines can be 

thought of as model regulations that States use in developing State plans to implement the 

emission guidelines. If a State does not develop, adopt, and submit an approvable State plan, the 

Environmental Protection Agency (EPA) must develop a Federal plan to implement the emission 

guidelines. Existing CISWI units are units that commenced construction on or before the date of 

proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart 

DDDD.

In general, all emission guidelines require initial notifications, performance tests, and 

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

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

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

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

and are required of all affected facilities subject to the emission guidelines. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

Over the next three years, we estimate that 57 existing facilities (respondents) with 82 

CISWI units per year will be subject to the standard, and no additional respondents per year will 

become subject to the standard. 

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

without any “Terms of Clearance”.
The “Affected Public” are owners and operators of existing CISWI units who will be 

affected by the State Plan. The burden to the “Affected Public” may be found in Table 1: 

Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid 

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

Designated Administrator refers to the person or office designated by each State plan to 

administer and implement the plan, or to the U.S. EPA Administrator in the event that a State’s 

plan is not approvable and a Federal plan must be developed. Their burden is attributed entirely

to work performed by state employees, federal employees, or government contractors, and is 

presented in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for 

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

DDDD) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

. . . prescribe regulations which shall establish a procedure similar 

to that provided by section 110 under which each State shall 

submit to the Administrator a plan which (A) establishes standards 

of performance for any existing source for any air pollutant (i) for 

which air quality criteria have not been issued or which is not 

included on a list published under section 108(a) . . . but (ii) to 

which a standard of performance under this section would apply if 

such existing source were a new source, and (B) provides for the 

implementation and enforcement of such standards of 

performance.

The EPA is required under section 129 of the Act, to establish guidelines for existing 

stationary sources that reflect the maximum achievable control technology (MACT) for 

achieving continuous emission reductions:

Section 129(a)(1)(A) states:

The Administrator shall establish performance standards and other 

requirements pursuant to section 111 and this section for each 

category of solid waste incineration units. Such standards shall 

include emissions limitations and other requirements applicable to 

new units and guidelines (under section 111(d) and this section) 

and other requirements applicable to existing units.

Section 129(a)(2) states:

Standards applicable to solid waste incineration units promulgated 
under section 111 and this section shall reflect the maximum 

degree of reduction in emissions of air pollutants listed under 

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

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

health and environmental impacts and energy requirements, 

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

Section 129(b)(1) states:

Performance standards under this section and section 111 for solid 

waste incineration units shall include guidelines promulgated 

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

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

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

limitations, notwithstanding any restriction in section 111(d) 

regarding issuance of such limitations), subsection (c) 

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

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

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

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

states that:

the Administrator may require any person who owns or operates 

any emission source, who manufactures emission control 

equipment or process equipment, who the Administrator believes 

may have information necessary for the purposes set forth in this 

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

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

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

or continuous basis to -

(A) establish and maintain such records;

(B) make such reports;

(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
4

(G) provide such other information, as the 

Administrator may reasonably require; . . . .

Certain reports are necessary to enable a Designated Administer to identify existing 

sources subject to the State plan that implements the emission guidelines and the determine if the 

standards are being achieved.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

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

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

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

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

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

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

determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

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

installed and operated, and/or leaks are being detected and repaired, and the standard is being 

met. The performance test may also be observed.

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

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

determinations.

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

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

DDDD.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.
5

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations 

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of all compliance data. 

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

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted the National Waste & Recycling Association at 

(202) 364-3724, the Portland Cement Association at aohare@cement.org, and the Energy

Recovery Council at (202) 467-6240.

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

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

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

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

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

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

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

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

is based. The retention of records for five years allows EPA to establish the compliance history
6

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and 

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

code for the respondents affected by the standard, and the corresponding North American 

Industry Classification System (NAICS) codes are listed below. 

Standard (40 CFR Part 60, Subpart 

DDDD)

SIC Codes NAICS Codes

Wood Product Manufacturing NA 321

Chemical Manufacturing NA 325

Wholesale Trade, Durable Goods NA 421

Furniture and Related Product 

Manufacturing

NA 337

 

4(b) Information Requested

(i) Data Items

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

Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 
7

60, Subpart DDDD) (Renewal).

A source must make the following reports:

Notifications / Reports

Submit final control plan 60.2600(a)

Submit notification of final compliance 60.2605 

Submit waste management plan 60.2755 

Report the following information no later than 60 days after the initial 

performance test:

- complete test report for the initial performance test results

- the values for site-specific operating limits 

60.2760 

Closure notification report 60.2615 

Report the following information annually:

- company name and address

- certification by responsible official

- date of report and beginning and ending dates of reporting period

- the values for the site-specific operating parameters

- the highest maximum operating parameter and the lowest 

minimum operating parameter

- information on deviations and malfunctions

- the results of performance tests conducted during the period, if 

any

- if no deviations or malfunctions occurred during the period, a 

statement that no exceedances occurred

- documentation of periods when all qualified CISWI unit 

operators were unavailable for more than 8 hours

60.2765, 

60.2770 

If a deviation from operating limits or emission limitations occurs, 

submit a deviation report that includes the following information:

- date of deviation

- the data for that date

- the reason for the deviation

- the corrective actions that were taken

 60.2775, 

 60.2780 

If all qualified operators are unavailable for more than 2 weeks, submit a 

notification of the deviation within 10 days and a corrective action 

summary every 4 weeks

60.2785

If an increment of progress is not met, submit a notification each month 

until increment is met

60.2595
8

A source must keep the following records:

Recordkeeping

5-year retention of records 60.2740

Calendar date of each record. 60.2740(a)

Records of operating parameters. 60.2740(b)

Records of days when a deviation from the operating limits have 

occurred. Includes a description of the deviation and a description of the 

corrective actions taken. 

60.2740(e)

Records of initial performance tests, annual performance tests, and any

subsequent performance tests.

60.2740(f)

Records of names of persons who have completed review of the sitespecific information and incinerator operating procedures in 60.2660(c).60.2740(g)

Records of names of persons who have completed the operator training 

requirements. Includes documentation of the training and the dates of the 

training.

60.2740(h)

Records of phone and/or pager number of persons who have met the 

operator qualification criteria.

60.2740(i)

Records of calibration of any monitoring devices. 60.2740(j)

Equipment vendor specifications for the incinerator, emission controls, 

and monitoring equipment.

60.2740(k)

Daily log of quantity and types of waste burned. 60.2740(m)

Records of annual control device inspections. 60.2740(n)

Records of site-specific information and incinerator operation 

procedures.

60.2660(c)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

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

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

a plant site. 

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

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

widely used. At this time, it is estimated that approximately 0 percent of the respondents use 

electronic reporting. 
9

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, O2 (or CO2), SO2, NOx, and CO. 

Perform initial and annual stack tests for dioxins/furans, cadmium, lead, mercury, particulate 

matter, opacity, hydrogen chloride, and fugitive ash. 

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

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

reports, required to be submitted by industry.
10

Agency Activities

Audit facility records.

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

5(b) Collection Methodology and Management

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

determine whether the pollution control devices are properly installed and operated. 

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

with the emission standard (note the operating conditions under which compliance was 

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

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

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

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

Based on Small Business Administration guidelines, approximately 6 small businesses 

are affected by this rule. The EPA does not expect the standards to have a significant small 

business impact.

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

entities. However, the rule does contain several provisions that reduce the impact of the rule on 

regulated entities, which include small entities. These are: annual performance testing is only

required for three pollutants rather than the full ten pollutants included in the initial performance 

test for some subcategories; operating parameter monitoring is required instead of continuous 

emissions monitoring systems (CEMS) for some subcategories; the owner or operator is allowed 

to skip two annual performance tests for a pollutant if all performance tests over the previous 

3 years show compliance within a certain threshold of the emission limit; and deviation reports 

are only required if there is a deviation, otherwise reporting is annual.
11

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for 

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

DDDD) (Renewal). 

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

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

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

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

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

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 7,378 (Total Labor Hours from Table 1a through 

1e, and 1f – Summary of Respondents Burden and Cost below). These hours are based on 

Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the Emission Guidelines, the previously approved ICR, and any 

comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $122.56 ($58.36+ 110%) 

Technical $56.32 ($26.82 + 110%)

Clerical $35.11 ($16.72 + 110%)

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

2012, National Industry-Specific Occupational Employment and Wage Estimates. These are 

average rates for the following sectors: Pulp, Paper and paperboard Mills; Pipeline 

Transportation; Cement and Concrete Product Manufacturing; Pharmaceutical & Medicine 

Manufacturing. The rates have been increased by 110 percent to account for the benefit packages 

available to those employed by private industry.
12

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Annual stack test

- Incinerator NA $55,200 3 $165,600

- ERU, solid NA $55,200 22 $1,214,400

- small remote 

incinerator

NA $55,200 28 $1,545,600

- ERU, liquid NA $55,200 6 $331,200

- cement kiln NA $40,867 23 $939,933

CMS 1

- Incinerator NA $13,167 3 $39,500

- ERU, solid NA $43,218 22 $950,794

- small remote 

incinerator

NA $5,736 28 $160,600

- ERU, liquid NA $10,467 6 $62,800

- cement kiln NA $124,361 23 $2,860,300

Photocopy and postage

- annual report NA $7.50 82 $615

- semiannual 

report

NA $7.50 8.2 $61.50

TOTAL $8,271,404

NA – not applicable

1 Calculated based on the number of CMS units. O&M cost per respondent for CMS is calculated by dividing total 

O&M cost by the number of respondents for that sector. 

The total capital/startup costs for this ICR are zero. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $8,271,404. This is 

the total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 
13

industry over the next three years of the ICR is estimated to be $8,271,404. These are 

recordkeeping costs. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$66,460. 

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

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

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

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

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

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

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

based appear below in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines 

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

DDDD) (Renewal). 

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

57 existing respondents (facilities) with 82 CISWI units will be subject to the standard. It is 

estimated that no additional respondents per year will become subject. The overall average 

number of respondents, as shown in the table below, is 57 per year. The total estimated number 

of respondents consists of 3 incinerators at 3 facilities, 22 solid energy recovery units at 13 

facilities, 28 small remote incinerators at 24 facilities, 6 liquid/gas energy recovery units at 4 

facilities, and 23 cement kilns at 13 facilities. 

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

years covered by this ICR. 
14

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 57 0 0 57

2 0 57 0 0 57

3 0 57 0 0 57

Average 0 57 0 0 57

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 57. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of initial 

performance test

0 1 0 0

Notification of initial CMS 

demonstration

0 1 0 0

Report of initial performance test 0 1 0 0

Report of initial CMS 

demonstration

0 1 0 0

Report prior to construction 0 1 0 0

Report prior to initial start-up 0 1 0 0

Report of initial stack test 0 1 0 0

Report to establish values for sitespecific operating parameters0 1 0 0
15

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Waste management plan 0 1 0 0

Annual report of performance test 

results

82 1 0 82

Status report for operators that are 

off-site for more than 2 weeks

8.2 1 0 8.2

Corrective action summary for 

operators that are off-site for 

more than 2 weeks

8.2 2 0 16.4

Semiannual report of exceedance 8.2 1 0 8.2

Total 114.8

The number of Total Annual Responses is 115 (rounded). 

The total annual labor costs are $423,197. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – Emission Guidelines for 

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

DDDD) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 7,378 at a cost of $423,197. Details regarding these 

estimates may be found below in Table 1a through 1e, and 1f – Summary of Respondents 

Burden and Cost. Annual Respondent Burden and Cost – Emission Guidelines for Commercial 

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

(Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 64 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $8,271,404. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 
16

Maintenance (O&M) Costs.

(ii) The Agency Tally

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

1,475 labor hours at a cost of $66,460. See below in Table 2: Average Annual EPA Burden and 

Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration (CISWI) 

Units (40 CFR Part 60, Subpart DDDD) (Renewal).

6(f) Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to an adjustment. 

The change in the burden and cost estimates occurred because the standard has been in effect for 

more than three years and the requirements are different during initial compliance as compared 

to on-going compliance. The previous ICR reflected those burdens and costs associated with the 

initial activities for subject facilities. This includes purchasing monitoring equipment, 

conducting performance tests and establishing recordkeeping systems. This ICR, by in large, 

reflects the on-going burden and costs for existing facilities. Activities for existing source 

include continuously monitoring of pollutants and the submission of annual performance test 

results and semiannual reports of exceedances. The overall result is a decrease in burden hours

and labor costs. However, there is an increase in the total O&M costs as this ICR reflects the 

burden associated with annual performance testing requirement of the Emission Guidelines. 

In addition to the changes above, this ICR revises the number of respondents using the 

latest Agency estimates, and corrects the number of responses as the previous ICR incorrectly 

included internal records as a response. This attributes to a decrease in the number of 

respondents and number of responses. 

6(g) Burden Statement

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

is estimated to average 64 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.
17

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2013-0312. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

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

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

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2013-0312 and OMB Control Number 2060-0664 in any

correspondence. 

Part B of the Supporting Statement

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

information.
18

Table 1a: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal), Incinerators

(A) (B) (C) (D) (E) (F) (G)

Burden Item

Technical 

hours per 

occurrence

Number of occurrence 

per respondent per year

Hours per 

occurrence

Number of

respondents

Technica

l hours

Manageme

nt hours

Cleric

al

hours

Total labor 

cost per 

year

(C=A x B) (a) (CXD) (E x 0.05) (E x 

0.1) (b)

1. Applications Not applicable

2. Surveys and Studies Not applicable

3. Reporting Requirements

A. Read and Understand Rule Requirements (c, d, l) 1 1 1 0 0 0 0 $0 

B. Required Activities (c)

1) Initial stack test and report (PM, dioxins/furans, See E 1 0 0 0 0 0 $0 

 opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as 

required))

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

and Fugitive Ash) (e) See E 1 0 3 0 0 0 $0 

3) Operator training and qualification (c, e)

a) Establish and teach operator qualification 

course

64 1 64 0 0 0 0 $0 

b) Obtain operator qualification 72 1 72 0 0 0 0 $0 

c) Annual refresher course 12 1 12 3 36 1.8 3.6 $2,374.59 

d) Initial review of site-specific information See a.

e) Annual review of site-specific information 8 1 8 3 24 1.2 2.4 $1,583.06 

4) Establish operating parameters (maximum and 

minimum) (c) 40 1 40 0 0 0 0 $0 

5) Continuous parameter monitoring (including CEMS)

a) Initial costs (c, f) 17 1 17 0 0 0 0 $0 

b) Annual costs (e, g) 17 1 17 3 51 2.55 5.1 $3,364.00 

C. Create Information See 3.B

D. Gather Information See 3.E
19

E. Report Preparation

1) Notification of initial performance test

a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0 

b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0 

2) Notification of initial CMS Demonstration 2 1 2 0 0 0 0 $0 

3) Report of initial performance test

a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0 

b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0 

4) Report of initial CMS demonstration See 3.B.5

5) Report prior to construction (includes siting analysis) (c) 160 1 160 0 0 0 0 $0 

6) Report prior to initial start-up (c, h)

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

b) With site specific parameter petition 14 1 14 0 0 0 0 $0 

7) Report of initial stack test See 3.B.1

8) Report established values for site-specific operating 

parameters (c) See 3.B 1 0 0 0 0 0 $0 

9) Waste management plan (c) 160 1 160 0 0 0 0 $0 

10) Annual Report:

a) Results of performance tests conducted during 

the year 40 1 40 3 120 6 12 $7,915.29 

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

than 2 weeks (i) 8 1 8 0.3 2.4 0.12 0.24 $158.31 

12) Corrective action summary for operators that are offsite for more than 2 weeks (i)

8 2 16 0.3 4.8 0.24 0.48 $316.61 

13) Semiannual report of emissions/parameter exceedances

(j) 24 1 24 0.3 7.2 0.36 0.72 $474.92 

F. Affirmative Defense Claim (m) 30 0 0 0 0 0 0 $0 

Subtotal for Reporting Requirements 282 $16,187 

4. Recordkeeping Requirements

A. Read Instructions See 3.A
20

B. Plan Activities N/A

C. Implement Activities N/A

D. Develop Record System N/A

E. Record Information

1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0 

2) Records of periods for which minimum amount of data on 

operating parameters were not obtained (k)

0.5 52 26 0 0 0 0 $0 

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

4) Records of exceedances of the operating parameters (j) 1.5 1 1.5 0.3 0.45 0.02 0.05 $29.68 

5) Records of stack tests See 3.E

6) Records of siting analysis See 3.E

7) Records of persons who have reviewed operating 

procedures 1 1 1 3 3 0.15 0.3 $197.88 

8) Records of persons who have completed operator training 1 1 1 3 3 0.15 0.3 $197.88 

9) Records of persons who meet operator qualification criteria 1 1 1 3 3 0.15 0.3 $197.88 

10) Records of monitoring device calibration See 3.B

11) Records of site-specific documentation 24 1 24 3 72 3.6 7.2 $4,749.17 

F. Personnel Training See 3.B

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 

94 $5,373

TOTAL ANNUAL BURDEN AND COSTS (rounded)

376 $21,559 

FOOTNOTES

a

Based on the total number of existing units expected to continue operating once the guidelines become effective.

b

Costs are based on the following hourly rates: technical at $34.60, management at $82.23, clerical at $22.32, and testing contractor at $80. 

c

One-time only costs.
21

d

Cost incurred by a facility regardless of the number of affected units at the plant.

e

Annual cost. Annual costs are not incurred until the second year of operation.

f Based on the sum of the annualized capital costs for each monitoring system required for incinerators. 

g Based on the sum of the calculated annual cost for each monitoring system required for incinerators. 

h Assumed that one-third of the facilities will petition for site-specific parameters.

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

Assumed that this required only two corrective action summaries.

j Assumed that 10 percent of the facilities would have an exceedance during the year. 

k Standards apply at all times under the newly proposed regulation. Therefore no periods of unobtained data or malfunction periods are 

expected.

l Assumed $100 for purchase of filing cabinet to house copy of rule, records and report copies.

m Assumed no affirmative defense claims would be filed in the first three years after promulgation. If a source were to meet the notification, 

reporting, and recordkeeping requirements of affirmative defense, it would be approximately 30 hours or around $3,100 in labor burden.
22

Table 1b: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal), Energy Recovery Units (ERU), Solid

(A) (B) (C) (D) (E) (F) (G)

Burden Item

Technical 

hours per 

occurrence

Number of 

occurrence per 

respondent per 

year

Hours per 

occurrence

Number of 

respondents

Technical 

hours

Management 

hours

Clerical 

hours

Total labor 

cost per year

(C=A x B) (a) (CXD) (E x 0.05) (E x 0.1) (b)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements c, d, l 1 1 1 0 0 0 0 $0 

B. Required Activities

1) Initial stack test and report (PM, dioxins/furans, 

opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required))c See E 1 0 0 0 0 0 $0 

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

Opacity, and Fugitive Ash) e See E 1 0 22 0 0 0 $0 

3) Operator training and qualification c, e

a) Establish and teach operator qualification course 64 1 64 0 0 0 0 $0 

b) Obtain operator qualification 72 1 72 0 0 0 0 $0 

c) Annual refresher course 12 1 12 13 156 7.8 15.6 $10,289.88 

d) Initial review of site-specific information See a.

e) Annual review of site-specific information 8 1 8 13 104 5.2 10.4 $6,859.92 

4) Establish operating parameters (maximum and 

minimum) c 40 1 40 0 0 0 0 $0 

5) Continuous parameter monitoring (including 

CEMS)

a) Initial costs c, f 17 1 17 0 0 0 0 $0 

b) Annual costs e, g 17 1 17 0 0 0 0 $0 

C. Create Information See 3.B

D. Gather Information See 3.E

E. Report Preparation
23

1) Notification of initial performance test

a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0 

b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0 

2) Notification of initial CMS Demonstration 2 1 2 0 0 0 0 $0 

3) Report of initial performance test

a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0 

b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0 

4) Report of initial CMS demonstration See 3.B.5

5) Report prior to construction (includes siting analysis)

c

160 1 160 0 0 0 0 $0 

6) Report prior to initial start-up

c, h

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

b) With site specific parameter petition 14 1 14 0 0 0 0 $0 

7) Report of initial stack test See 3.B.1

8) Report established values for site-specific operating 

parameters

c See 3.B 1 0 0 0 0 0 $0 

9) Waste management plan

c

160 1 160 0 0 0 0 $0 

10) Annual Report:

a) Results of performance tests conducted during the year 40 1 40 22 880 44 88 $58,045.45 

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

than 2 weeks

i 8 1 8 2.2 

17.6 0.88 1.76 $1,160.91 

12) Corrective action summary for operators that are 

off-site for more than 2 weeks

i 8 2 16 2.2 35.2 1.76 3.52 $2,321.82 

13) Semiannual report of emissions/parameter 

exceedances

j 24 1 24 2.2 52.8 2.64 5.28 $3,482.73 

F. Affirmative Defense Claim

m

30 0 0 0 0 0 0 $0 

Subtotal for Reporting Requirements 1,432 $82,161 

4. Recordkeeping Requirements

A. Read Instructions See 3.A

B. Plan Activities N/A
24

C. Implement Activities N/A

D. Develop Record System N/A

E. Record Information

1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0 

2) Records of periods for which minimum amount of 

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

3) Records of malfunction of the unit k

1.5 1 1.5 0 0 0 0 $0 

4) Records of exceedances of the operating parameters j

(j)

1.5 1 1.5 2.2 3.3 0.17 0.33 $217.67 

5) Records of stack tests See 3.E

6) Records of siting analysis See 3.E

7) Records of persons who have reviewed operating 

procedures 1 1 1 13 13 0.65 1.3 $857.49 

8) Records of persons who have completed operator 

training 1 1 1 13 13 0.65 1.3 $857.49 

9) Records of persons who meet operator qualification 

criteria 1 1 1 13 13 0.65 1.3 $857.49 

10) Records of monitoring device calibration See 3.B

11) Records of site-specific documentation 24 1 24 13 312 15.6 31.2 $20,579.75 

F. Personnel Training See 3.B

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 407 $23,370

TOTAL ANNUAL BURDEN AND COSTS (rounded) 1,840 $105,531 

FOOTNOTES

a

Based on the total number of existing units expected to continue operating once the guidelines become effective.

b

Costs are based on the following hourly rates: technical at $34.60, management at $82.23, clerical at $22.32, and testing contractor at $80. 

c

One-time only costs.

d

Cost incurred by a facility regardless of the number of affected units at the plant.

e

Annual cost. Annual costs are not incurred until the second year of operation.

f Based on the sum of the annualized capital costs for each monitoring system required for incinerators. 

g Based on the sum of the calculated annual cost for each monitoring system required for incinerators. 
25

h Assumed that one-third of the facilities will petition for site-specific parameters.

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

Assumed that this required only two corrective action summaries.

j Assumed that 10 percent of the facilities would have an exceedance during the year. 

k Standards apply at all times under the newly proposed regulation. Therefore no periods of unobtained data or malfunction periods are 

expected.

l Assumed $100 for purchase of filing cabinet to house copy of rule, records and report copies.

m Assumed no affirmative defense claims would be filed in the first three years after promulgation. If a source were to meet the notification, 

reporting, and recordkeeping requirements of affirmative defense, it would be approximately 30 hours or around $3,100 in labor burden.
26

Table 1c: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal), Small, Remote Incinerators

Burden Item (A) (B) (C) (D) (E) (F) (G)

Technical 

hours per 

occurrence

Number of 

occurrence 

per 

respondent 

per year

Hours per 

respondent 

per year

 Number of 

respondents

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours 

per year

Total labor 

costs per year

(C=A x B) (a) (CXD) (E x 0.05) (E x 0.1) (b)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements c, d, l 1 1 1 0 0 0 0 $0 

B. Required Activities c, e, f, g

1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, 

Hg, CO, NOx, and SO2 (as required)) See E. 1 0 0 0 0 0 $0 

2) Annual stack test and test report (PM, HCl, Opacity, and Fugitive Ash) See E. 1 0 28 0 0 0 $0 

3) Operator training and qualification 

a) Establish and teach operator qualification course 64 1 64 0 0 0 0 $0 

b) Obtain operator qualification 72 1 72 0 0 0 0 $0 

c) Annual refresher course 12 1 12 24 288 14.4 28.8 $18,996.69 

d) Initial review of site-specific information See a.

e) Annual review of site-specific information 8 1 8 24 192 9.6 19.2 $12,664.46 

4) Establish operating parameters (maximum and minimum) 40 1 40 0 0 0 0 $0 

5) Continuous parameter monitoring (including CEMS)

a) Initial costs 17 1 17 0 0 0 0 $0 

b) Annual costs 17 1 17 0 0 0 0 $0 

C. Create Information See 3.B

D. Gather Information See 3.E

E. Report Preparation
27

1) Notification of initial performance test

a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0 

b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0 

2) Notification of initial CMS Demonstration 2 1 2 0 0 0 0 $0 

3) Report of initial performance test

a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0 

b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0 

4) Report of initial CMS demonstration See 3.B.5

5) Report prior to construction (includes siting analysis) c

160 1 160 0 0 0 0 $0 

6) Report prior to initial start-up

c, h

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

b) With site specific parameter petition 14 1 14 0 0 0 0 $0 

7) Report of initial stack test See 3.B.1

8) Report established values for site-specific operating parameters c

See 3.B 1 0 0 0 0 0 $0 

9) Waste management plan 160 1 160 0 0 0 0 $0 

10) Annual Report:

a) Results of performance tests conducted during the year 40 1 40 28 1,120 56 112 $73,876.03 

11) Status report for operators that are off-site for more than 2 weeks i

8 1 8 2.8 22.4 1.12 2.24 $1,477.52 

12) Corrective action summary for operators that are off-site for more than 2 

weeks i 8 2 16 2.8 44.8 2.24 4.48 $2,955.04 

13) Semiannual report of emissions/parameter exceedances j

24 1 24 2.8 67.2 3.36 6.72 $4,432.56 

F. Affirmative Defense Claim m

30 0 0 0 0 0 0 $0 

Subtotal for Reporting Requirements 1,995 $114,402 

4. Recordkeeping Requirements

A. Read Instructions See 3.A

B. Plan Activities N/A

C. Implement Activities N/A

D. Develop Record System N/A
28

E. Record Information

1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0 

2) Records of periods for which minimum amount of data on operating 

parameters were not obtained k 0.5 52 26 0 0 0 0 $0 

3) Records of malfunction of the unit k

1.5 1 1.5 0 0 0 0 $0 

4) Records of exceedances of the operating parameters j

1.5 1 1.5 2.8 4.2 0.21 0.42 $277.04 

5) Records of stack tests See 3.E

6) Records of siting analysis See 3.E

7) Records of persons who have reviewed operating procedures 1 1 1 24 24 1.2 2.4 $1,583.06 

8) Records of persons who have completed operator training 1 1 1 24 24 1.2 2.4 $1,583.06 

9) Records of persons who meet operator qualification criteria 1 1 1 24 24 1.2 2.4 $1,583.06 

10) Records of monitoring device calibration See 3.B

11) Records of site-specific documentation 24 1 24 24 576 28.8 57.6 $37,993.38 

F. Personnel Training See 3.B

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 750 $43,020

TOTAL ANNUAL BURDEN AND COSTS (rounded): 2,745 $157,422 

FOOTNOTES

a

Based on the total number of existing units expected to continue operating once the guidelines become effective.

b

Costs are based on the following hourly rates: technical at $34.60, management at $82.23, clerical at $22.32, and testing contractor at $80. 

c

One-time only costs.

d

Cost incurred by a facility regardless of the number of affected units at the plant.

e

Annual cost. Annual costs are not incurred until the second year of operation.

f Based on the sum of the annualized capital costs for each monitoring system required for incinerators. 

g Based on the sum of the calculated annual cost for each monitoring system required for incinerators. 

h Assumed that one-third of the facilities will petition for site-specific parameters.

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

Assumed that this required only two corrective action summaries.

j Assumed that 10 percent of the facilities would have an exceedance during the year. 

k Standards apply at all times under the newly proposed regulation. Therefore no periods of unobtained data or malfunction periods are 
29

expected.

l Assumed $100 for purchase of filing cabinet to house copy of rule, records and report copies.

m Assumed no affirmative defense claims would be filed in the first three years after promulgation. If a source were to meet the notification, 

reporting, and recordkeeping requirements of affirmative defense, it would be approximately 30 hours or around $3,100 in labor burden.
30

Table 1d: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal), Energy Recovery Units (ERU), Liquid/Gas

Burden Item (A) (B) (C) (D) (E) (F) (G)

Technical hours 

per occurrence

Number of 

occurrence 

per 

respondent 

per year

Hours per 

respondent 

per year

 Number of 

respondents

Technical 

hours per 

year

Manageme

nt hours 

per year

Clerical 

hours per 

year

Total labor 

costs per year

(C=A x B) (a) (CXD) (E x 0.05) (E x 0.1) (b)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements c, d, l 1 1 1 0 0 0 0 $0 

B. Required Activities

1) Initial stack test and report (PM, dioxins/furans, opacity, HCl, 

Cd, Pb, Hg, CO, NOx, and SO2 (as required)) c See E. 1 0 0 0 0 0 $0 

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

Fugitive Ash) e See E. 1 0 6 0 0 0 $0 

3) Operator training and qualification 

a) Establish and teach operator qualification course c

64 1 64 0 0 0 0 $0 

b) Obtain operator qualification c

72 1 72 0 0 0 0 $0 

c) Annual refresher course e12 1 12 4 48 2.4 4.8 $3,166.12 

d) Initial review of site-specific information See a.

e) Annual review of site-specific information e

8 1 8 4 32 1.6 3.2 $2,110.74 

4) Establish operating parameters (maximum and minimum) c

40 1 40 0 0 0 0 $0 

5) Continuous parameter monitoring (including CEMS)

a) Initial costs c, f 17 1 17 0 0 0 0 $0 

b) Annual costs e, g 17 1 17 0 0 0 0 $0 

C. Create Information See 3.B

D. Gather Information See 3.E
31

E. Report Preparation

1) Notification of initial performance test

a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0 

b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0 

2) Notification of initial CMS Demonstration 2 1 2 0 0 0 0 $0 

3) Report of initial performance test

a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0 

b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0 

4) Report of initial CMS demonstration See 3.B.5

5) Report prior to construction (includes siting analysis) c

160 1 160 0 0 0 0 $0 

6) Report prior to initial start-up 

c, h

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

b) With site specific parameter petition 14 1 14 0 0 0 0 $0 

7) Report of initial stack test See 3.B.1

8) Report established values for site-specific operating parameters 

(c) See 3.B 1 0 0 0 0 0 $0 

9) Waste management plan c

160 1 160 0 0 0 0 $0 

10) Annual Report:

a) Results of performance tests conducted during the year 40 1 40 6 240 12 24 $15,830.58 

11) Status report for operators that are off-site for more than 2 

weeks i 8 1 8 0.6 4.8 0.24 0.48 $316.61 

12) Corrective action summary for operators that are off-site for 

more than 2 weeks i 8 2 16 0.6 9.6 0.48 0.96 $633.22 

13) Semiannual report of emissions/parameter exceedances j

24 1 24 0.6 14.4 0.72 1.44 $949.83 

F. Affirmative Defense Claim m

30 0 0 0 0 0 0 $0 

Reporting Subtotal 401 $23,007 

4. Recordkeeping Requirements

A. Read Instructions See 3.A

B. Plan Activities N/A
32

C. Implement Activities N/A

D. Develop Record System N/A

E. Record Information

1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0 

2) Records of periods for which minimum amount of data on 

operating parameters were not obtained k 0.5 52 26 0 0 0 0 $0 

3) Records of malfunction of the unit k

1.5 1 1.5 0 0 0 0 $0 

4) Records of exceedances of the operating parameters j

1.5 1 1.5 0.6 0.9 0.05 0.09 $59.36 

5) Records of stack tests See 3.E

6) Records of siting analysis See 3.E

7) Records of persons who have reviewed operating procedures 1 1 1 4 4 0.2 0.4 $263.84 

8) Records of persons who have completed operator training 1 1 1 4 4 0.2 0.4 $263.84 

9) Records of persons who meet operator qualification criteria 1 1 1 4 4 0.2 0.4 $263.84 

10) Records of monitoring device calibration See 3.B

11) Records of site-specific documentation 24 1 24 4 96 4.8 9.6 $6,332.23 

F. Personnel Training See 3.B

G. Time for Audits N/A

Recordkeeping Subtotal 125 $7,183

TOTAL: 526 $30,190 

FOOTNOTES

a

Based on the total number of existing units expected to continue operating once the guidelines become effective.

b

Costs are based on the following hourly rates: technical at $34.60, management at $82.23, clerical at $22.32, and testing contractor at $80. 

c

One-time only costs.

d

Cost incurred by a facility regardless of the number of affected units at the plant.

e

Annual cost. Annual costs are not incurred until the second year of operation.

f Based on the sum of the annualized capital costs for each monitoring system required for incinerators. 

g Based on the sum of the calculated annual cost for each monitoring system required for incinerators. 

h Assumed that one-third of the facilities will petition for site-specific parameters.
33

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

Assumed that this required only two corrective action summaries.

j Assumed that 10 percent of the facilities would have an exceedance during the year. 

k Standards apply at all times under the newly proposed regulation. Therefore no periods of unobtained data or malfunction periods are 

expected.

l Assumed $100 for purchase of filing cabinet to house copy of rule, records and report copies.

m Assumed no affirmative defense claims would be filed in the first three years after promulgation. If a source were to meet the notification, 

reporting, and recordkeeping requirements of affirmative defense, it would be approximately 30 hours or around $3,100 in labor burden.
34

Table 1e: Annual Respondent Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste Incineration 

(CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal), Waste-Burning Cement Kilns

(A) (B) (C) (D) (E) (F) (G)

Technical hours per 

occurrence

Number of 

occurrence per 

respondent per 

year

Hours per 

respondent per 

year

 Number of 

respondents

Technical hours 

per year

Management 

hours per year

Clerical hours 

per year

Total labor 

costs per year

(C=A x B) (a) (CXD) (E x 0.05) (E x 0.1) (b)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements c, d, l 1 1 1 0 0 0 0 $0 

B. Required Activities

1) Initial stack test and report (PM, dioxins/furans, 

opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2 (as required)) c See E. 1 0 0 0 0 0 $0 

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

and Fugitive Ash) e See E. 1 0 23 0 0 0 $0 

3) Operator training and qualification 

a) Establish and teach operator qualification course c

64 1 64 0 0 0 0 $0 

b) Obtain operator qualification c

72 1 72 0 0 0 0 $0 

c) Annual refresher course e

12 1 12 13 156 7.8 15.6 $10,289.88 

d) Initial review of site-specific information See a.

e) Annual review of site-specific information e

8 1 8 13 104 5.2 10.4 $6,859.92 

4) Establish operating parameters (maximum and 

minimum) c 40 1 40 0 0 0 0 $0 

5) Continuous parameter monitoring (including CEMS)

a) Initial costs c, f 17 1 17 0 0 0 0 $0 

b) Annual costs e, g 17 1 17 0 0 0 0 $0 

C. Create Information See3.B

D. Gather Information See3.E

E. Report Preparation
35

1) Notification of initial performance test

a) Pollutants, fugitive ash emissions 2 1 2 0 0 0 0 $0 

b) Fugitive Ash Emissions 1 1 1 0 0 0 0 $0 

2) Notification of initial CMS Demonstration 2 1 2 0 0 0 0 $0 

3) Report of initial performance test

a) Pollutants, fugitive ash emissions 8 1 8 0 0 0 0 $0 

b) Fugitive Ash Emissions 2 1 2 0 0 0 0 $0 

4) Report of initial CMS demonstration See3.B.5

5) Report prior to construction (includes siting analysis) 

c

160 1 160 0 0 0 0 $0 

6) Report prior to initial start-up 

c, h

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

b) With site specific parameter petition 14 1 14 0 0 0 0 $0 

7) Report of initial stack test See3.B.1

8) Report established values for site-specific operating 

parameters c See3.B 1 0 0 0 0 0 $0 

9) Waste management plan c 160 1 160 0 0 0 0 $0 

10) Annual Report:

a) Results of performance tests conducted during the 

year

40 1 40 23 920 46 92 $60,683.88 

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

than 2 weeks 

i 8 1 8 2.3 18.4 0.92 1.84 $1,213.68 

12) Corrective action summary for operators that are offsite for more than 2 weeks i 8 2 16 2.3 36.8 1.84 3.68 $2,427.36 

13) Semiannual report of emissions/parameter 

exceedances 

j 24 1 24 2.3 55.2 2.76 5.52 $3,641.03 

F. Affirmative Defense Claim 

m

30 0 0 0 0 0 0 $0 

Reporting Subtotal 1,484 $85,116 

4. Recordkeeping Requirements

A. Read Instructions See3.A

B. Plan Activities N/A

C. Implement Activities N/A
36

D. Develop Record System N/A

E. Record Information

1) Records of operating parameters See 3.B.5.b 52 0 0 0 0 0 $0 

2) Records of periods for which minimum amount of data 

on operating parameters were not obtained k 0.5 52 26 0 0 0 0 $0 

3) Records of malfunction of the unit k

1.5 1 1.5 0 0 0 0 $0 

4) Records of exceedances of the operating parameters j

1.5 1 1.5 2.3 3.45 0.17 0.35 $227.56 

5) Records of stack tests See 3.E

6) Records of siting analysis See 3.E

7) Records of persons who have reviewed operating 

procedures 1 1 1 13 13 0.65 1.3 $857.49 

8) Records of persons who have completed operator 

training 1 1 1 13 13 0.65 1.3 $857.49 

9) Records of persons who meet operator qualification 

criteria 1 1 1 13 13 0.65 1.3 $857.49 

10) Records of monitoring device calibration See 3.B

11) Records of site-specific documentation 24 1 24 13 312 15.6 31.2 $20,579.75 

F. Personnel Training See 3.B

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 408 $23,380

TOTAL: 1,892 $108,496 

FOOTNOTES

a

Based on the total number of existing units expected to continue operating once the guidelines become effective.

b

Costs are based on the following hourly rates: technical at $34.60, management at $82.23, clerical at $22.32, and testing contractor at $80. 

c

One-time only costs.

d

Cost incurred by a facility regardless of the number of affected units at the plant.

e

Annual cost. Annual costs are not incurred until the second year of operation.

f Based on the sum of the annualized capital costs for each monitoring system required for incinerators. 

g Based on the sum of the calculated annual cost for each monitoring system required for incinerators. 

h Assumed that one-third of the facilities will petition for site-specific parameters.

i Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assumed that this required only two corrective action 
37

summaries.

j Assumed that 10 percent of the facilities would have an exceedance during the year. 

k Standards apply at all times under the newly proposed regulation. Therefore no periods of unobtained data or malfunction periods are expected.

l Assumed $100 for purchase of filing cabinet to house copy of rule, records and report copies.

m Assumed no affirmative defense claims would be filed in the first three years after promulgation. If a source were to meet the notification, reporting, and recordkeeping requirements of 

affirmative defense, it would be approximately 30 hours or around $3,100 in labor burden.

Table 1f: Summary of Respondent Burden and Cost 

CISWI Unit Type Reporting 

Hours

Recordkeeping 

Hours Total Hours Labor Costs

Incinerator 282 94 376 $21,559

ERU, solid 1,432 407 1,840 $105,531

Small, remote incinerator 1,995 750 2,745 $157,422

ERU, liquid/gas 401 125 526 $30,190

Cement kilns 1,484 408 1,892 $108,496

Respondent Total 5,594 1,784 7,378 $423,197
38

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Commercial and Industrial Solid Waste 

Incineration (CISWI) Units (40 CFR Part 60, Subpart DDDD) (Renewal)

(A) (B) (C) (D) (E) (F)

Burden Item

Number of 

Occurrences 

Per Year

EPA Hours 

Per 

Occurrence

Tech 

Hours 

Per Year 

(C=AxB)

Management 

Hours Per 

Year 

(D=Cx0.05)

Clerical 

Hours Per 

Year 

(E=Cx0.1)

EPA Cost 

Per Year 

(a,b)

1. Applications not applicable

2. Read and Understand Rule Requirements 0 c 16 0 0 0 $0 

3. Required Activities

A. Observe initial stack tests

(PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2) 0 c,d 48 0 0 0 $0 

B. Excess emissions -- Enforcement Activities 8.2 f 24 196.8 9.84 19.68 $10,199.06

C. Create Information not applicable

D. Gather Information not applicable

E. Report Reviews

1) Review waste management plan and siting analysis 0 c 8 0 0 0 $0 

2) Review report submitted prior to initial startup 0 c 2 0 0 0 $0 

3) Review initial stack test report 0 c 40 0 0 0 $0 

4) Review annual compliance report 82 e 8 656 32.8 65.6 $33,996.87

5)

Review semi-annual excess emission and parameter exceedance report 8.2 f 16 131.2 6.56 13.12 $6,799.37 

6) Review status reports and corrective action summary for operators off-site 24.6 g 4 98.4 4.92 9.84 $5,099.53 

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

TOTAL 1,475 $66,460 

FOOTNOTES

a

Costs are based on the following hourly rates (loaded with 60% for fringe and overhead): technical at $52.37, management at $86.56, clerical at $29.52.

b Figures may not add exactly due to rounding.
39

c One-time only costs.

d Assumes EPA personnel attend 20 percent of the initial stack tests.

e Burden not incurred until second year of operation onward.

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

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

submitted.