1847ss08

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), EPA ICR Number 1847.08, OMB Control Number 2060-0390.

1(b) Short Characterization/Abstract

The Emission Guidelines for Large Municipal Waste Combustors at 40 CFR Part 60, Subpart Cb were proposed on September 20, 1994, promulgated on December 19, 1995, and amended on August 25, 1997, and May 10, 2006. These regulations apply to existing facilities constructed on or before September 20, 1994 that own and operate municipal waste combustion (MWC) units with a combustion capacity greater than 250 tons per day of municipal solid waste (large MWC units). The reporting and recordkeeping requirements discussed below result from the emission guidelines that apply to large MWCs covered by EPA-approved and effective State plans and, where a State plan has not been approved, large MWCs covered by the Federal plan. This information is being collected to assure compliance with 40 CFR part 60, subpart Cb.

In general, all Emission Guidelines standards 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 Emission Guidelines.

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least five years following the generation date of such 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.

The “Affected Public” includes MWC units that are owned by the private sector, MWC units that are owned by state and local government, as well as State Administrators. The burden to the “Affected Public” may be found below in Table 1a: Annual Privately Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), and in Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal). The burden to the “Designated State Administrator” is attributed entirely to work performed by either the state, or local, or tribal air pollution authority employees or government contractors and may be found below in Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by other Federal employees or by government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).

There are 159 large MWC units located at 62 MWC plants (respondents) in 19 States subject to the emission guidelines through either State or the Federal plans. Of the 62 large MWC plants, 53 plants are located in 15 states with State plans; nine plants are located in 4 states without State plans and are thus subject to the Federal plan. There are approximately 39 large MWC plant (63%) that are privately owned and operated by the MWC industry. Approximately 23 large MWC plants (37%) in the United States are owned by state, local, tribal or the Federal government. In addition to the 62 large MWC plants, it is estimated that there are 15 State Designated Administrators.

Based on our consultations with industry representatives, there are an average of 2.6 affected facilities at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 77 respondents per year (62 MWC plants and 15 Designated Administrators) will be subject to the standard, and no additional respondents per year will become subject to the standard. The Emission Guidelines only apply to sources constructed on or before September 20, 1994.

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)(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

(G) provide such other information, as the Administrator may reasonably require; . . . .

In the Administrator's judgment, particulate matter, opacity, sulfur dioxide, hydrogen chloride, oxides of nitrogen, carbon monoxide, lead, cadmium, mercury, and dioxins and dibenzofurans emissions from MWCs cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the Emission Guidelines were promulgated for this source category at 40 CFR Part 60, Subpart Cb.

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 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, 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. Nonduplication, Consultations, and Other Collection Criteria

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

3(a) Nonduplication

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 83 FR 24785 on May 30, 2018. No comments were received on the burden published in the Federal Register for this renewal.

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 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 77 respondents will be subject to the standard over the three-year period covered by this ICR.

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: 1) the Solid Waste Association of North America (SWANA), at (800) 467-9262; 2) the National Waste & Recycling Association (NWRA), at (202) 244-4700; and 3) Covanta, at (862) 345-5000.

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 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 large MWC units. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for large MWC units are provided in the following table.

Standard (40 CFR Part 60, Subpart Cb)	SIC Codes	NAICS Codes
Air and Water Resource and Solid Waste Management	9511	92411
Refuse System; Solid Waste Combustors and Incinerators	4953	562213

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported are required by the Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb).

State/US protectorates must perform the following requirements:

Requirement
Submit a state plan	§§60.39b(b), 60.23(a)
Notification of public hearing on State Plan	§60.23(d)
Certification that public hearing on State Plan conducted according to part 60 Subpart B State procedures	§60.23(f)
Negative Declaration, if applicable	§62.06

A source must make the following reports:

Notifications
Notification of completion of each increment of progress, including final control plan	§60.39b(c)(1)(i)
Notification of exemptions	§§60.32b(b)(1), (d), (e), (f)(1), (i)(1)
Notification of initial performance tests (PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg, fugitives)	§60.8(d)
Notification of starting or stopping use of the particulate matter, cadmium, lead, mercury, hydrogen chloride, and dioxin/furan continuous emission monitoring systems or continuous automated sampling systems.	§60.59b(m)

Reports
Report initial performance tests for all regulated pollutants and parameters	§60.59b(f),
Report of Continuous Emissions Monitoring System (CEMS) demonstration and test data	§60.59b(f)(3)
Annual compliance reports for all pollutants and parameters	§60.59b(g)
Air Curtain incinerator records	§60.59b(i)
Semiannual excess emission reports (SO2, CO, load, temperature, PM, dioxin/furan, opacity, HCl, Cd, Pb, Hg, fugitives)	§60.59b(h)

A source must keep the following records:

Recordkeeping
Records of public hearing conducted on State Plan	§60.23(e)
Records of calendar date of each record	§60.59b(d)(1)
Records of CEMS concentration rates and parameters and computations of average emissions and parameters	§§60.59b(d)(2), (n)
Records of exceedances, data availability	§§60.59b(d)(3), (d)(6), (d)(7), (h)
Records of activated carbon for Hg and dioxin/furan control	§§60.59b(d)(4), (d)(14), (d)(15)
Records of results of daily CEMS drift tests, and Appendix F accuracy assessments	§§60.59b(d)(8), (d)(10)
Records of initial performance tests and annual performance tests, including final control plan	§§60.59b(d)(9), (f), (g), (i)
Records of the occurrence and duration of any startup, shutdown, or malfunction of the facility or any malfunction of the CEM	§§60.59b(d), (n), (o)
Records of operator training, availability and corrective action	§60.59b(d)(12)
Records of names of persons who have completed review of operating manual	§60.59b(d)(13)
Records of opacity limits for air curtain incinerators burning 100% yard waste	§60.59b(e)
Records are required to be retained for 5 years at the facility	§§60.59b(d), (e), (j)

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 continuous emissions monitoring systems for sulfur dioxide, nitrogen oxides, opacity, carbon monoxide, load level, temperature of the fuel gas stream, and oxygen or carbon dioxide.

Perform initial performance test, applicable Reference Method test, 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 collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for 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. 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 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

There are no small entities (i.e., small businesses) affected by this regulation.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in below Table 1a: Annual Privately Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), and Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal).

6. Estimating the Burden and Cost of the Collection

Tables 1a through 1c document 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 394,000 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the EG program, 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 $147.40 ($70.19+ 110%)

Technical $117.92 ($56.15 + 110%)

Clerical $57.02 ($27.15 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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.

Additionally, this ICR assumes a contractor rate of $188.26. The contractor rate was derived by taking the contractor rate in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR. The result is a seven percent increase in contractor rate since the last ICR. The labor rates for publicly owned sources and State administrators are detailed in Section 6(c).

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

The type of industry costs associated with the information collection activities in the subject standard(s) 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)
Private sector- Load monitors, temperature monitors, and carbon feed rate monitors.	$100,000	0	$0	$9,600	104	$998,000
Public sector -Load monitors, temperature monitors, and carbon feed rate monitors.	$100,000	0	$0	$9,600	55	$528,000
Total		0	$0		159	$1,530,000

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

¹ Since the Emission Guidelines only apply to sources that commenced construction on or before September 20, 1994, no additional MWC units will become subject to the standard over the next three years.

² Approximately 159 sources located at 62 plants are currently subject to the Emissions Guidelines and each source requires continuous monitoring. Of the 159 sources, 104 sources are within the private sector and 55 sources are publicly owned.

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 $1,530,000. 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 $1,530,000. 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 $23,600.

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

Managerial $65.71 (GS-13, Step 5, $41.07 + 60%)

Technical $48.75 (GS-12, Step 1, $30.47 + 60%)

Clerical $26.38 (GS-6, Step 3, $16.49 + 60%)

These rates are from the Office of Personnel Management (OPM), 2018 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 Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (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 77 existing respondents will be subject to the standard. The estimate includes 62 MWC plants and 15 State Designated Administrators. 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 77 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

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	77	0	0	77
2	0	77	0	0	77
3	0	77	0	0	77
Average	0	77	0	0	77

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

² An average of 62 large MWC plants (respondents) will be subject to the standards over the next three years. Approximately 39 respondents are privately owned and 23 respondents are publicly owned. Additionally, it is estimated there will 15 State Designated Administrators. Total number of respondents = (62 + 15) = 77.

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 77.

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
Privately owned large MWCs
Increments of Progress (Plant Control Plan, notifications, etc.)	0	3	0	0
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc.	0	4	0	0
Annual Performance Tests and Reports	39	1	0	39
Annual Compliance Reports	39	1	0	39
Semiannual Excess Emission Reports	8	2	0	16
			Total	94
Publicly owned large MWCs
Increments of Progress (Plant Control Plan, notifications, etc.)	0	3	0	0
Initial Testing Notifications and Reports (Performance Test, CEMS Demonstration, etc.	0	4	0	0
Annual Performance Tests and Reports	23	1	0	23
Annual Compliance Reports	23	1	0	23
Semiannual Excess Emission Reports	5	2	0	10
			Total	56
Designated State Plan Administrators
Excess Emissions – Enforcement Activities	11	1	0	11
Review Annual Compliance Report	53	1	0	53
Review Semiannual Excess Emissions Report	11	1	0	11
			Total	75

The number of Total of Annual Responses is 225. This total includes: 1) 94 for privately owned MWCs; 2) 56 for publicly owned MWCs; and 3) 75 for designated State plan administrators.

The total annual labor costs are $62,200,000. Details regarding these estimates may be found below in Tables 1a: Annual Privately Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal), and Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (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 1a, 1b, 1c, and 2 below, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 394,000. Details regarding these estimates may be found in Tables 1a, 1b, and 1c.

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 1,750 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,530,000. 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 497 labor hours at a cost of $23,600. See Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (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 a small adjustment decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This decrease in labor hours is not due to any program changes. Instead, the slight decrease is due to a decrease in the number of respondents, and several minor adjustments and updates to the calculations based on new information collected by the Agency. Two units were discovered to be affected by the Federal plan instead of the State Plan, and thus decreased the burden for Designated State Administrators. In addition, several units were determined to be privately owned rather than publicly owned based on new data. There was a slight decrease in capital/startup and O&M costs because the number of units changed.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,750 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2012-0503. 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-2012-0503 and OMB Control Number 2060-0390 in any correspondence.

Part B of the Supporting Statement

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

Table 1a: Annual Privately Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)

Burden Item	(A) Respondent Person Hours Per Occurrence	(B) Contractor Person Hours Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Hours Per Respondent Per Year (D=AxC)	(E) Number of Respondents Per Year a	(F) Technical Hours Per Year (F=DxE)	(G) Management Hours Per Year (G=Fx0.05)	(H) Clerical Hours Per Year (H=Fx0.1)	(I) Contractor Hours Per Year (I=BxCxE)	(J) Total Costs Per Year b
1.) Applications	N/A
2.) Surveys and Studies	N/A
3.) Reporting Requirements
A. Familiarize with Regulatory Requirementsc	40	0	1	40	39	1,560	78	156	0	$204,347.52
B. Required Activities
1) Initial performance tests and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)	24	750	1	24	0	0	0	0	0	$0
b) Repeat of Initial performance tests d	24	750	1	24	0	0	0	0	0	$0
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a) Installation of CEM units	24	200	1	24	0	0	0	0	0	$0
b) Initial demonstration	24	430	1	24	0	0	0	0	0	$0
c) Repeat of initial demonstration d	24	430	1	24	0	0	0	0	0	$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)
a) Plants that do not qualify for reduced D/F testing with 2 units	24	1,500	1	24	1	24	1.2	2.4	1,500	$285,533.81
b) Plants that do not qualify for reduced D/F testing with 3 units	24	2,250	1	24	2	48	2.4	4.8	4,500	$853,457.62
c) Plants that qualify for reduced D/F testing with 2 units	24	1,428	1	24	13	312	15.6	31.2	18,564	$3,535,728.14
d) Plants that qualify for reduced D/F testing with 3 units	24	2,106	1	24	15	360	18	36	31,590	$5,994,290.52
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year)e	8	350	1	8	104	832	41.6	83.2	36,400	$6,961,649.34
b) RAA audit (three per year)e	8	130	3	24	104	2,496	124.8	249.6	40,560	$7,962,781.63
c) Daily calibration and operation	1	0	365	365	104	37,960	1,898	3,796	0	$4,972,456.32
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Plant startup
a) Control plan	40	0	1	40	0	0	0	0	0	$0
b) Notification of contract awards	4	0	1	4	0	0	0	0	0	$0
c) Notification of on-site construction start	4	0	1	4	0	0	0	0	0	$0
d) Notification of construction completion	4	0	1	4	0	0	0	0	0	$0
e) Notification of final compliance	4	0	1	4	0	0	0	0	0	$0
2) Notification of initial performance tests	4	0	1	4	0	0	0	0	0	$0
3) Initial performance tests reports	40	0	1	40	0	0	0	0	0	$0
4) Notification of CEMS demonstration	4	0	1	4	0	0	0	0	0	$0
5) Initial CEMS demonstration report	90	0	1	90	0	0	0	0	0	$0
6) Notification of starting or stopping use of the CEMS	4	0	1	4	0	0	0	0	0	$0
7) Air Curtain incinerator initial performance tests	4	0	1	4	0	0	0	0	0	$0
8) Annual compliance reports	40	0	1	40	39	1,560	78	156	0	$204,347.52
9) Semi-annual excess emission reports f	40	0	2	80	8	640	32	64	0	$83,834.88
10) Notification of exemptions	4	0	1	4	0	0	0	0	0	$0
Subtotal for Reporting						185,775				$31,058,427
4.) Recordkeeping Requirements
A. Familiarize with Regulatory Requirementsc	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Record information
1) Record startups, shutdowns, and malfunctions g	4	0	47	188	104	19,552	977.6	1,955	0	$2,561,155.58
2) Records of all emission rates, computations, tests g	4	0	47	188	104	19,552	977.6	1,955	0	$2,561,155.58
3) Records of employee review of operations manual	4	0	1	4	39	156	7.8	15.6	0	$20,434.75
4) Record amount of sorbent used for Hg and dioxin/furan control h	4	0	4	16	104	1,664	83.2	166.4	0	$217,970.69
5) Records of emission exceedances and periods when emission data not obtained	See 3E
6) Records of CEMS drift tests and Appendix F accuracy assessments	See 4E 1-4
7) Records of initial performance test	See 3E
8) Records of annual performance tests	See 3E
9) Records of opacity limits for air curtain incinerators	See 3E
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping						47,063				$5,360,717
TOTAL LABOR BURDEN AND COST (Rounded)i						233,000				$36,400,000
Capital and O&M Cost i										$998,000
GRAND TOTAL i										$37,400,000
Assumptions:
a. There are 159 large MWC units located at 62 MWC plants. Of these, there are 104 large MWC units at 39 plants that are privately owned.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of labor Statistics, June 2018, 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. The contractor rate was derived by taking the contractor rate used in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume 20 percent of reporting plants must repeat initial tests due to failure at one unit at the plant.
e. RATA audits are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Based on weekly recordkeeping, we assume 47 weeks of operation (90 percent availability) per year per MWC.
h. Based on quarterly calculation of sorbent use for entire plant, regardless of the number of affected facilities at the plant.
i. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 1b: Annual Publicly Owned Respondent Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)

Burden Item	(A) Respondent Person Hours Per Occurrence	(B) Contractor Person Hours Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Hours Per Respondent Per Year (D=AxC)		(E) Number of Respondents Per Year a		(F) Technical Hours Per Year (F=DxE)	(G) Management Hours Per Year (G=Fx0.05)		(H) Clerical Hours Per Year (H=Fx0.1)		(I) Contractor Hours Per Year (I=BxCxE)				(J) Total Costs Per Year b
1.) Applications	N/A
2.) Surveys and Studies	N/A
3.) Reporting Requirements
A. Familiarize with Regulatory Requirements c	40	0	1	40		23		920	46		92		0				$120,512.64
B. Required Activities
1) Initial performance tests and reports
a) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)	24	750	1	24		0		0	0		0		0				$0
b) Repeat of Initial performance tests d	24	750	1	24		0		0	0		0		0				$0
2) CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)
a) Installation of CEM units	24	200	1	24		0		0	0		0		0				$0
b) Initial demonstration	24	430	1	24		0		0	0		0		0				$0
c) Repeat of initial demonstration d	24	430	1	24		0		0	0		0		0				$0
3) Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)
a) Plants that do not qualify for reduced D/F testing with 2 units	24	1,500	1	24		3		72	3.6		7.2		4,500				$856,601.42
b) Plants that do not qualify for reduced D/F testing with 3 units	24	2,250	1	24		2		48	2.4		4.8		4,500				$853,457.62
c) Plants that qualify for reduced D/F testing with 2 units	24	1,428	1	24		14		336	16.8		33.6		19,992				$3,807,707.23
d) Plants that qualify for reduced D/F testing with 3 units	24	2,106	1	24		16		384	19.2		38.4		33,696				$6,393,909.89
4) Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a) RATA audit (one per year)e	8	350	1	8		55		440	22		44		19,250				$3,681,641.48
b) RAA audit (three per year)e	8	130	3	24		55		1,320	66		132		21,450				$4,211,086.44
c) Daily calibration and operation	1	0	365	365		55		20,075	1,003.8		2,008		0				$2,629,664.40
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Plant startup
a) Control plan	40	0	1	40		0		0	0		0		0				$0
b) Notification of contract awards	4	0	1	4		0		0	0		0		0				$0
c) Notification of on-site construction start	4	0	1	4		0		0	0		0		0				$0
d) Notification of construction completion	4	0	1	4		0		0	0		0		0				$0
e) Notification of final compliance	4	0	1	4		0		0	0		0		0				$0
2) Notification of initial performance tests	4	0	1	4		0		0	0		0		0				$0
3) Initial compliance reports	40	0	1	40		0		0	0		0		0				$0
4) Notification of CEMS demonstration	4	0	1	4		0		0	0		0		0				$0
5) Initial CEMS demonstration report	90	0	1	90		0		0	0		0		0				$0
6) Notification of starting or stopping use of the CEMS	4	0	1	4		0		0	0		0		0				$0
7) Air Curtain incinerator initial performance tests	4	0	1	4		0		0	0		0		0				$0
8) Annual compliance reports	40	0	1	40		23		920	46		92		0				$120,512.64
9) Semi-annual excess emission reports f	40	0	2	80		4.6		368	18.4		36.8		0				$48,205.06
10) Notification of exemptions	4	0	1	4		0		0	0		0		0				$0
Subtotal for Reporting								132,003									$22,723,299
4.) Recordkeeping Requirements
A. Familiarize with Regulatory Requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Record information
1) Record startups, shutdowns, and malfunctions g	4	0	47	188		55		10340	517		1034		0				$1,354,457.28
2) Records of all emission rates, computations, tests g	4	0	47	188		55		10340	517		1034		0				$1,354,457.28
3) Records of employee review of operations manual	4	0	1	4		23		92	4.6		9.2		0				$12,051.26
4) Record amount of sorbent used for Hg and dioxin/furan control h	4	0	4	16		55		880	44		88		0				$115,272.96
5) Records of emission exceedances and periods when emission data not obtained f	See 3E
6) Records of CEMS drift tests and Appendix F accuracy assessments	See 4E 1-4
7) Records of initial performance test	See 3E
8) Records of annual performance tests	See 3E
9) Records of opacity limits for air curtain incinerators	See 3E
F. Personnel training	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping								24,900									$2,836,239
TOTAL LABOR BURDEN AND COST (Rounded)i								157,000									$25,600,000
Capital and O&M Cost i																	$528,000
GRAND TOTAL i																	$26,100,000
Assumptions:
a. There are 159 large MWC units located at 62 MWC plants. Of these, there are 55 large MWC units at 23 plants that are publicly owned.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of labor Statistics, June 2018, 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. The contractor rate was derived by taking the contractor rate used in the previous ICR and multiplying by the average increase in managerial, technical, and clerical rates since the previous ICR.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume 20 percent of reporting plants must repeat initial tests due to failure at one unit at the plant.
e. RATA audits are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Based on weekly recordkeeping, we assume 47 weeks of operation (90 percent availability) per year per MWC.
h. Based on quarterly calculation of sorbent use for entire plant, regardless of the number of affected facilities at the plant.
i. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 1c: Average Annual Designated Administrator Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)

Burden Item	(A) Number of Occurrences Per Year a	(B) Administrator Hours Per Occurrence	(C) Technical Hours Per Year (C=AxB)	(D) Management Hours Per Year (D=Cx0.05)	(E) Clerical Hours Per Year (E=Cx0.1)	(F) Administrator Costs Per Year b
1.) Applications	N/A
2.) Familiarize with Regulatory Requirements c	15	40	600	30	60	$32,804.10
3.) Required Activities
A. Develop a state plan	0	2,080	0	0	0	$0
B. Public Hearing on state plan	0	8	0	0	0	$0
A. Observe initial performance tests
1) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)d	0	48	0	0	0	$0
2) Repeat of initial performance tests e	0	10	0	0	0	$0
B. Excess emissions -- enforcement activities f	11	24	264	13.2	26.4	$14,433.80
C. Create Information
D. Gather Information
E. Report Reviews
1) Control plan	0	8	0	0	0	$0
2) Notification of contract awards	0	8	0	0	0	$0
3) Notification of on-site construction start	0	8	0	0	0	$0
4) Notification of construction completion	0	8	0	0	0	$0
5) Notification of final compliance	0	8	0	0	0	$0
6) Review notification of initial performance test	0	8	0	0	0	$0
7) Review notification of initial CEMS demonstration	0	4	0	0	0	$0
8) Review notification of starting or stopping use of the CEMS	0	8	0	0	0	$0
9) Review initial performance test report	0	40	0	0	0	$0
10) Review initial CEMS demonstration report	0	40	0	0	0	$0
11) Review annual compliance report g	53	40	2,120	106	212	$115,907.82
12) Review semi-annual excess emission report f	11	16	176	8.8	17.6	$9,622.54
13) Review of notifications of exemption	0	4	0	0	0	$0
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)h			3,630			$173,000
Assumptions:
a. Assume 140 affected units as 53 plants in 15 states.
b. The cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule, which excludes locality rates of pay.
c. This ICR assumes all respondents will have to familiarize with regulatory requirements
d. Assume EPA personnel attend about 8 percent of tests.
e. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests.
f. Assume 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
g. Burden not incurred until second year of operation and later.
h. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Large Municipal Waste Combustors Constructed on or Before September 20, 1994 (40 CFR Part 60, Subpart Cb) (Renewal)

Burden Item	(A) Number of Occurrences Per Year a	(B) Administrator Hours Per Occurrence	(C) Technical Hours Per Year (C=AxB)	(D) Management Hours Per Year (D=Cx0.05)	(E) Clerical Hours Per Year (E=Cx0.1)	(F) Administrator Costs Per Year b
1.) Applications	N/A
2.) Familiarize with Regulatory Requirements	0	40	0	0	0	$0
3.) Required Activities
A. Observe initial performance tests
1) Initial performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCI, Cd, Pb, Hg)c	0	48	0	0	0	$0
2) Repeat of initial performance tests d	0	10	0	0	0	$0
B. Excess emissions -- enforcement activities e	1.8	24	43.2	2.16	4.32	$2,361.90
C. Create Information
D. Gather Information
E. Report Reviews
1) Control plan	0	8	0	0	0	$0
2) Notification of contract awards	0	8	0	0	0	$0
3) Notification of on-site construction start	0	8	0	0	0	$0
4) Notification of construction completion	0	8	0	0	0	$0
5) Notification of final compliance	0	8	0	0	0	$0
6) Review notification of initial performance test	0	8	0	0	0	$0
7) Review notification of initial CEMS demonstration	0	4	0	0	0	$0
8) Review notification of starting or stopping use of the CEMS	0	8	0	0	0	$0
9) Review initial performance test report	0	40	0	0	0	$0
10) Review initial CEMS demonstration report	0	40	0	0	0	$0
11) Review annual compliance report f	9	40	360	18	36	$19,682.46
12) Review semi-annual excess emission report e	1.8	16	28.8	1.44	2.88	$1,574.60
13) Review of notifications of exemption	0	4	0	0	0	$0
F. Prepare annual summary report	0	200	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)g			497			$23,600
Assumptions:
a. Assumes 22 affected units at 9 facilities in 4 states without State Plans and thus are subject to the Federal Plan.
b. The cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule, which excludes locality rates of pay.
c. Assume EPA personnel attend about 8 percent of tests.
d. Assume a 20 percent failure rate and that EPA personnel attend 10 percent of the retests.
e. Assumes 20 percent of affected plants must submit two semiannual reports per year due to exceeding one or more pollutant emission limits.
f. Burden not incurred until second year of operation and later.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.