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). 

The Emission Guidelines apply 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 subcategories: very small municipal waste combustion (VSMWC) 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 guidelines 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 

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 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 the 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 entities 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 – Emission 
Guideline for Existing Other Solid Waste Incineration Units (40 CFR Part 60, Subpart FFFF) 

(Renewal). The “burden” to the Federal Government is attributed entirely to work performed 

by either Federal 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 standards, and no additional respondents per year will become subject to these same

standards. These standards apply 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 this 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 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) 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 control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

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.
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2(b) Practical Utility/Users of the Data

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

applicable regulations which were promulgated in accordance with the Clean Air Act. 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards 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, that leaks are being detected and repaired, and that the standards are being 

met. The performance test may also be observed.

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

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

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart

FFFF.

3(a) Non-duplication

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

appropriate EPA regional office. Otherwise, the information is sent 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 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 (80 FR 32116) on June 5, 2015. 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 
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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 Integrated Compliance Information System (ICIS). ICIS is 

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

and government-owned facilities. 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 

standards over the three-year period covered by this ICR.

Industry trade association and other interested parties were provided an opportunity 

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

standards have been reviewed previously to determine the minimum information 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 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-ear statute of limitations on which the permit program is 

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

a source, any 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.
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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 (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

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 OSWI units. The 

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

standards, and the corresponding 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 813410
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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 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:

Notifications

Notification 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, 60.3051

Waste management plan 60.3010, 60.3011, 

60.3012

Semiannual report of deviation 60.3052, 603053

A source must keep the following records:
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Recordkeeping

Data collected for all operating parameters used to determine 

compliance 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 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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CEMS for carbon monoxide and for oxygen. 

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

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities

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

storage, and distribution of the required information:

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 in 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. ICIS 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 and 
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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

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 requirements 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 scale 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 Guideline 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 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 70,200. These hours are based on Agency studies 

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

experience with the NSPS program, the previously approved ICR, and any comments received.
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6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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. The capital/startup costs are one-time costs when a 

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

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

(iii) 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 of 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 the 
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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 

$394,000. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (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. 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 these Emission Guidelines. These 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 respondents, as shown 

in the table below, is 99 per year.

The number of respondents is calculated using the following tables that address the three 

years covered by this ICR: 
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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.

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 99.

The total number of annual responses per year is calculated using the following table: 
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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 plan 0 1 0 0

Negative declaration 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 $7,060,000. 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 70,200 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 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 time required for technical tasks because the typical duties of 

clerical staff are 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.
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The total annual capital/startup and O&M costs 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 CFR 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 time 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 labor 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, effort, 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 requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information.

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

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

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

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

Docket ID Number EPA-HQ-OECA-2011-0256. An electronic version of the public docket is 
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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), 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 is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA-HQ-OECA-2011-0256 and OMB Control Number 2060-0562 in any 

correspondence. 

Part B of the Supporting Statement

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

information.
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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

Personhours

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. Reporting 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 $274,773.71

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 preparation
18

Burden item

A B C D E F G H

Personhours

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 ANNUAL 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 † ) $7,560,000 

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 hour for Technical labor, and $51.79 per hour for 

Clerical labor. 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.

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 operation per year, Model 1 = 121 days/yr. For 

consistency, 250 operating days are assumed for all models. Emission testing hours (0.25 hr/occurrence) accounts for periodic contractor operation and maintenance support. 

Annual hours averaged to a daily basis.

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

† 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 

personhours

per 

occurrence

No. of 

occurrences 

per plant 

per year

EPA personhours per 

plant per year 

(C=AxB)

Plants per 

year a

Technical 

personhours per 

year 

(E=CxD)

Management 

personhours per 

year 

(Ex0.05)

Clerical 

personhours 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 ANNUAL 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 guidelines. 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 overhead 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 affected 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.