SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60,

Subpart FFFF) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines for Existing Other Solid Waste Incineration Units (40 CFR Part 60,

Subpart FFFF) (Renewal) , EPA ICR Number 2164.05, OMB Control Number 2060

- 0562.

1(b) Short Characterization/Abstract

The Emission Guidelines for Existing Other Solid Waste Incineration (OSWI) Units (40

CFR Part 60, Subpart FFFF) were proposed on December 9, 2004 (69 FR 71471), promulgated

on December 16, 2005 (70 FR 74892), and amended on November 24, 2006 (71 FR 67806 )

. Th e Emission Guidelines appl y to any air quality program in either a state or a United States

protectorate with one or more existing OSWI units or air curtain incinerators that commenced

construction on or before December 9, 2004. The affected OSWI units include two su b

categories: very small municipal waste combustion (VSM WC) units that combust less than 35

tons per day of waste and institutional waste incineration (IWI) units. This subpart does not

directly affect incineration unit owners and operators; however, they must comply with the

state’s plan that was developed by the air quality program administrator to implement the

emission guidelines

. This information is being collected to assure compliance with 40 CFR Part

60, Subpart FFFF

.

In general, all emission guidel ines require initial notifications, performance tests,

one

- time 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

ma lfunction in the operation of an affected facility, or any period during which the monitoring

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

compliance, and are required of all affected facilities subject to NSPS.

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

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

maintenance reports, and records. All reports are sent to th e delegated state or local authority.

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

. S

. Environmental Protection Agency (EPA) regional office.

All of the OSWI units in the United States are owned and operated by the solid waste

incineration industry (the “Affected Public”). However, this ICR applies directly to the emission

guidelines with most of the units regulated by either state, or local, or tribal entitie s or by the

Federal government. They are considered not

- for

- profit businesses. The “ burden ” to the Affected

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

– EmissionGuideline for Existing Other Solid Waste Incineration Units (40 C FR Part 60, Subpart FFFF)

(Renewal)

. T he “ burden ” to the Federal Government is attributed entirely to work performed

by either F ederal employees or government contractors and may be found below in Table 2:

Average Annual EPA Burden and Cost

– NESHAP for Existing Other Solid Waste Incineration

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

.

Over the next three years, approximately 99 respondents per year will be subject to

the standard s , and no additional respondents per year will become subject to the se same

standard s

. Th ese standard s appl y to OSWI units that commenced construction on or before

December 9, 2004. Therefore, there will be no new units constructed during the period covered

by t his ICR.

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

without any “ Terms of Clearance ”

.

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 w hich (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 perf

ormance 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 exist ing

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 sec tion 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

sectio n (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), subsectio n (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) states

that the Administrator may require any owner/operator subject to any requirement of this Act to:

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

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

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

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

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

Administrator shall prescribe); (E) keep records on co ntrol

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 Admini strat or may

reasonably require.

In the Administrator's judgment, cadmium, carbon monoxide, dioxins/furans, hydrogen

chloride, lead, mercury, opacity, oxides of nitrogen, particulate matter, and sulfur dioxide

emissions from OSWI units either cause or contribute to air pollution that may reasonably be

anticipated to endanger public health and/ or welfare. Therefore, the emission guidelines were

promulgated for this source category at 40 CFR Part 60, Subpart FFFF

.4

2(b) Practical Utility/User s of the Data

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

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

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

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

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

ensure compliance with the standard s at all t imes. 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 , that leaks ar e being detected and repaired

, and that the standard s are being

met. The performance test may also be observed.

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

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

determinations.

3. Non

- duplication, Consultations, and Other Collection Criteria

The requested recordkeeping an d reporting are required under 40 CFR Part 60

, Subpart

FFFF.

3(a) Non

- duplication

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

appropriate EPA regional office. Otherwise, the information is sent 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.

3(b) Public No tice 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 ( 80 FR 32116 ) on June 5, 2015

. No comments were received on the

burden published in the Federal Regi ster

.

3(c) Consultations

The Agency has consulted i ndustry experts and internal data sources to project the5

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

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

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned fa cilities. The growth rate for the industry is based on our consultations

with the Agency’s internal industry experts. Approximately 99 respondents will be subject to the

standard s over the three

- year period covered by this ICR.

I ndustry trade association and other interested parties were provided an opportunity

to comment on the burden associated with the standard s as they was being developed and the

standard s ha ve been r eviewed previously to determine the minimum informati on needed for

compliance purposes. In developing this ICR, we contacted both the National Solid Waste

Management Association (NSWMA), at (202 ) 364

- 3773

, and the Solid Waste Association of

North America (SWANA), at (240) 494

- 2253.

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

ICR renewal as well as those submitted in response to the f irst Federal Register n otice. 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) Gen eral Guidelines

T hese 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

- ear statute of lim itations on which the permit program is

based. T he retention of records for five years allow s EPA to establish the compliance history of

a source

, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EPA has found t hat 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

.6

3(f) Confidentiality

Any information submitted t o 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

T he 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 OSWI units

. The

United States Standard Industrial Classification ( SIC ) code for the respondents affected by the

standards

, and the correspond ing North American Industry Classification System (NAICS)

codes, are listed in the following table :

Standard (40 CFR, Part 60, Subpart

FFFF) SIC Codes NAICS Codes

Solid Waste Combustors and Incinerators 4953 562213

Administration of Air and Waste Resource

and Solid Waste Management Programs 9511 924110

Nursing and Residential Care Facilities 8051, 8052, 8059, 8361 623

Justice, Public Order, and Safety Activities 9211, 9221, 9222, 9223,

9224, 9229, 8322 922

National Security and International Affairs 9711, 9721 928

Elementary and Secondary Schools 8211 611110

Junior Colleges 8222 611210

Colleges, Universities, and Professional

Schools 8221 611310

Museums, Historical Sites, and Similar

Institutions 8412, 8422, 7999 7121

Religious Organizations 8661 813110

Civic and Social Organizations 8641, 8699 8134107

4(b) Information Requested

(i) Data Items

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

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

State/US protectorates must perform the following requirements:

Requirement

Submit a state plan 60.2981

Submit a negative declaration 60.2982

A source must make the following reports:

Notification s

Notific ation of the date of construction or reconstruction 60.7(a)(1)

Notification of the actual date of initial startup 60.7(a)(3)

Notification of physical or operational change which may increase the

emission rate 60.7(a)(4)

Notification of performance test 60.7(a)(5)

Notification of operating limit deviation report 60.3052 and 60.3053

Notification of deviation 60.3054(a)(1)

Notification of status report 60.3054(a)(2)

Notification of resumed operation 60.3054(b)

Reports

Initial performance test and report 60.3049, 60.8(a)

Annual compliance test report 60.3050, 60.305 1

Waste management plan 60.3010, 60.3011,

60.3012

Semiannual report of deviation 60.3052, 603053

A source must keep the following records:8

Recordkeeping

D ata collected for all operating parameters used to determine

comp liance with the operating limits 60.3046(b)

, 60.3068(a)

Calendar dates, times, and durations of malfunctions, and a

description of the malfunction and the corrective action taken 60.3046(d)

Calendar dates and times for which monitoring systems used to

monitor operating limits were not functioning as intended, did not

collect the minimum amount of data required, or monitoring data

deviated from emissions limits 60.3046(c),(e) ,(f)

Calibration records 60.3046(h)

Results of all performance tests 60.3046(i)

Names, contact information, and training documentation for OSWI

unit operators 60.3046(j),(k),(l)

Equipment specifications, operation and maintenance procedures, and

waste management procedures for the incinerator and monitoring

systems 60.3019,

60.3046(m),(n)

Electronic Reporting

Some of the r espondents 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 recordke eping at

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate C E MS for carbon monoxide and for oxygen

.

Perform initial performance test, Reference Method 3A, 3B, and 26A test s , and repeat

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

systems for the purpose of collecting, validating, and verifying information.9

Respondent Activities

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

maintaining info rmation.

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 :

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 Enforcement and Compliance History Online (ECHO)

and ICIS.

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 and note the operating conditions under which compliance was achieved.

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

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

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

determinations.

Information contained i n the reports is reported by state and local governments in the

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial

and government

- owned facilities. EPA uses ICIS for tracking air pollution compliance and10

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

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

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

years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However,

the impact on small entities (i.e., small businesses) was taken into consideration during the

development of the regulation. Due to technical considerations involving the process operations

and the types of control equipment employed, the recordkeeping and reporting requireme nts are

the same for both small and large entities. The Agency considers these the minimum

requirements needed to ensure compliance and, therefore, cannot reduce them further for small

entities. To the extent that larger businesses can use economies of sca le to reduce their burden,

the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost

– Emission Guidelin e for Existing

Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).

6. Estimating the Burden and Cost of the Collection

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

reporting requirements applicable to the industry 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 an d

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 Cont rol Number.

6(a) Estimating Respondent Burden

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

and reporting requirement s is estimated to be 70, 2 00

. T hese hours are based on Agency studies

and background documen ts from the development of the regulation, Agency knowledge and

experience with the NSPS program, the previously approved ICR, and any comments received.11

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 66 + 110%)

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

2014

, “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from

column 1, “ Total compensation. ” The rates have been increased by 110 percent to account for

the benefit packages available to those employed by private industry.

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

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

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

associated with continuous monitoring. Th e capital/startup costs are one

- time costs when a

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

ongoing costs to maintain the monitor and other costs such as photocopying and posta ge.

(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)

Continuous emission

monitoring system $44,445 0 $0 $5,000 99 $495,000

$0 $495,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $ 0

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 495,000

. This is

the total of column G.

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

to industry over the next three years of the ICR is estimated to be $ 495,000

. These are the12

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 i ncludes activities such as the

examination of records maint ained 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

$ 394,000

.

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

These rates are from the Office of Personnel Management (OPM)

, 20 1 4 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 Guideline for

Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).

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

There are 55 States and U.S. territories subject to the se Emission Guidelines. The se are

the air quality programs in 50 States, one federal district, and four U.S. territories.

In addition, the regulations developed under the emissions guidelines apply to OSWI

units at approximately 99 existing facilities ( respondents )

. It is estimated that no additional

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

in the table below, is 99 per year.

The number of respondents is calculated using the following table s that ad dress the three

years covered by this ICR :13

Number of State and U.S. Protectorate

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 55 0 0 55

2 0 55 0 0 55

3 0 55 0 0 55

Average 0 55 0 0 55

Note: The respondents include the 50 States, one federal district (Washington D.C.), and four territories (America

Samoa, Puerto Rico, Virgin Islands, and Northern Mariana Islands). See 40 CFR Part 62.

1 New respondents are those who previously submitted a negative declaration but subsequently identify find a

OSWI unit.

Number of Respondents

– Facilities with OSWI Units

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 99 0 0 99

2 0 99 0 0 99

3 0 99 0 0 99

Average 0 99 0 0 99

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

C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the

average Number of Respondents over the three year period of this ICR is 99.

The total number of annual responses per year is calculated using the following table:14

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

State p lan 0 1 0 0

Negative d eclaration 0 1 0 0

Notification of final

compliance 0 1 0 0

Initial compliance report 0 1 0 0

Waste management plan 0 1 0 0

Annual compliance reports 99 1 0 99

Semiannual deviation reports 99 2 0 198

Total 297

The number of Total Annual Responses is 297.

The total annual labor costs are $7,0 6 0,000

. Details regarding these estimates may be

found below in Table 1: Annual Respondent Burden and Cost

– Emission Guideline for Existing

Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (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 below , respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 70, 2 00 hours

. Details regarding these estimates may be

found below in Table 1 : Annual Respondent Burden and Cost

– Emission Guideline for Existing

Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) (Renewal).

We assume that burdens for managerial ta sks take 5% of the time required for technical

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff a re to proofread the reports, make copies and maintain records.

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

information is estimated to average 236 hours per response

.15

The total annual capital/startup and O&M c osts to the regulated entity are $495,000

. The

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

(O&M) Costs.

(ii) The Agency Tally

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

$8,650 labor hours at a cost of $394,000 . See below Table 2: Average Annual EPA Burden and

Cost

– Emission Guideline for Existing Other Solid Waste Incineration Units (40 C FR Part 60,

Subpart FFFF) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens

are assumed to take 10% of the ti me required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated labor burden as currently identified

in the OMB Inventory of Approved Burdens. This not due to any program changes. The increase

occurred because we assume existing respondents will take some time to re

- familiarize

themselves with the rule each year. In addition, the cost estimate has been updated using more

current l abor rates.

6(g) Burden Statement

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

is estimated to average 236 hours per response. “ Burden ” means the total time, effo rt, or

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

information either 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 requirement s; 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 t his ICR under

Docket ID Number EPA

- HQ

- OECA

- 201 1

- 0256 . An electronic version of the public docket is16

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 numbe r identified

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

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

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

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

holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone

number for the docket center i s (202) 566

- 17 52

. 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

- 20 11

- 0256 and OMB C ontrol Number 2060

- 0562 in any

correspondence.

Part B of the Supporting Statement

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

information.17

Table 1: Annual Respondent Burden and Cost

– Emission Guideline for Existing Other Solid Waste Incineration Units (40

CFR Part 60, Subpart FFFF) (Renewal)

Burden item A B C D E F G H

Person

hours

per

occurrence Annual

occurrence

per

respondent Person

- hours

per respondent

per year

(AxB) Respondent

per year a Technical

hours

per year

(CxD) Management

hours

per year

(Ex0.05) Clerical

hours

per year

(Ex0.10) Annual cost

($) b

1. Applications

2. Surveys and studies

3. Report ing requirements

A

. Read and understand rule requirement c

New sources 40 1 40 0 0 0 0 $0

Existing sources 1 1 1 99 99 4.95 9.9 $11,448.90

B

. Required activities

1) Initial performance test and reports

a) Initial performance tests and test

reports (PM, dioxins/furans, opacity,

fugitives, HCl, Cd, Pb, Hg) c, d 24 1 24 0 0 0 0 $0

b) Repeat of initial performance tests d , e 24 1 24 0 0 0 0 $0

2) CEMS demonstration (CO, O2)

a) Repeat of initial demonstration e 229 1 229 0 0 0 0 $0

3) Annual performance tests and test

reports (PM, dioxins/furans, opacity,

fugitives, HCl, Cd, Pb, Hg) 24 1 24 99 2

, 376 118.8 237.6 $274,77 3.71

4) Quarterly Appendix F audits of CEMS

(CO)

a) RATA audit (one per year) f 4 1 4 99 396 19.8 39.6 $45,795.62

b) RAA audit (three per year) f 4 3 12 99 1

, 188 59.4 118.8 $137,386.85

c) Daily calibration and operation f, g 1 250 250 99 24

, 750 1

, 237.5 2

, 475 $2,862,226.13

C

. Create information See 3B

D

. Gather information See 3E

E

. Report preparation18

Burden item A B C D E F G H

Person

hours

per

occurrence Annual

occurrence

per

respondent Person

- hours

per respondent

per year

(AxB) Respondent

per year a Technical

hours

per year

(CxD) Management

hours

per year

(Ex0.05) Clerical

hours

per year

(Ex0.10) Annual cost

($) b

1) Contract of secure alternative means of

disposal d 40 1 40 0 0 0 0 $0

2) Notification of final compliance c, d 1.5 1 1.5 0 0 0 0 $0

3) Initial compliance report c, d 40 1 40 0 0 0 0 $0

4) Waste management plan c, d 40 1 40 0 0 0 0 $0

5) Annual compliance reports 40 1 40 99 3

, 960 198 396 $457,956.18

6) Semiannual deviation reports 24 2 48 99 4

, 752 237.6 475.2 $549,547.42

Subtotal for Reporting Requirements 43,149 $4,339,135

4 . Recordkeeping requirements

A

. Read and understand rule requirement c See 3A

B

. Plan activities See 3B

C

. Implement activities See 3B

D

. Develop record system N/A

E

. Record information

1) Records of SSM h 1.5 52 78 99 7

, 722 386.1 772.2 $893,014.55

2) Records of emission rate computations,

all emission exceedances and periods

when there is no data h 1.5 52 78 99 7

, 722 386.1 772.2 $893,014.55

3) Records of employee review of

operations manual 4 1 4 99 396 19.8 39.6 $45,795.62

4) Record of control devices operation

parameters h 1.5 52 78 99 7

, 722 386.1 772.2 $893,014.55

F

. Personnel training N/A

G

. Time for audits N/A

Subtotal for Recordkeeping Requirements 27,096 $2,724,839

TOTAL A NNUAL BURDEN AND COST (Rounded † ) 70,200 $7,060,000

Capital and O&M Cost (see section 6(b)(iii)) ( Rounded † ) $495,000

Grand Total ( Labor and Capital/O&M Costs ) ( Rounded † ) $7,5 6 0,000

Assumptions:19

a We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per h our for Technical labor, and $51.79 per hour for

Clerical labor. These rates are from the United States Department of Labor, Bur eau of Labor Statistics, June 2014 “Table 2: Civilian Workers, by occupational and industry group.”

The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit p ackages available to those emp loyed by private

industry.

c We assume existing sources will take one hour to re

- familiarize with rule requirements.

d We have assumed that all respondents have achieved final compliance for the emission guidelines.

e We have assumed that 20 percent of respondents will repeat initial tests due to failure.

f We have assumed that RATA audits are performed for one of the four quarterly audits, and RAA tests are performed for three of the four quarterly audits.

g We have assumed that each operation day requires a CEMS calibration; Combustor models 2, 3, and 4 assume 250 days of operatio n per year, Model 1 = 121 days/yr. For

consistency, 250 operating days are assumed for all models. Emission testing hours (0.2 5 hr/occurrence) accounts for periodic contractor operation and maintenance support.

Annual hours averaged to a daily basis.

h We have assumed that each respondent will record information 52 times per year.

† Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.20

Table 2: Average Annual EPA Burden and Cost

– Emission Guideline for Existing Other Solid Waste Incineration Units (40

CFR Part 60, Subpart FFFF) (Renewal)

Activity A B C D E F G H

EPA

p erson

hours

per

occurrence No. of

occurrences

per plant

per year EPA person

hours per

plant per year

(C=AxB) Plants per

year a Technical

person

hours per

year

(E=CxD) Management

person

hours per

year

(Ex0.05) Clerical

person

hours per

year

(Ex0.1) Cost, $ b

1. Prepare and submit State plan and negative

declaration N/A

2. Read and understand rule requirements N/A

3. Required activities

A. Create information N/A

B. Gather information See 3A

C. Report reviews

1) Notification of final compliance c 1.5 1 1.5 0 0 0 0 $0

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

3) Review annual compliance report 40 1 40 99 3960 198 396 $207,266

4) Review semiannual deviation reports 16 2 32 99 3168 158.4 316.8 $165,813

5) Review waste management plan c 16 1 16 0 0 0 0 $0

D. Annual summary report d 4 1 4 99 396 19.8 39.6 $20,727

TOTAL A NNUAL BURDEN AND COST (ROUNDED † ) 8,650 $394,000

Assumptions:

a We have assumed that there are approximately 99 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next

three years. We assume that all respondents have achieved final compliance for the emission guideline s. We also assume affected air quality program

administrator in States and U.S. territories have already submitted a State Plan and/or negative declaration.

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government o verhead expenses: $62.90 for

Managerial (GS

- 13, Step 5, $39.31 + 60%), $46.21 for Technical (GS

- 12, Step 1, $29.17 + 60%) and $25 .25 Clerical (GS

- 6, Step 3, $15.78 + 60%). These

rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay.

c We have assumed that this is a one

- time only cost.

d We have assumed that all affec ted facilities in the states will be required to prepare an annual summary plan.

† Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.