1926ss09

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal), EPA ICR Number 1926.09, OMB Control Number 2060-0450

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Commercial and Industrial Solid Waste Incineration (40 CFR Part 60, Subpart CCCC) were proposed on November 30, 1999; and promulgated on December 1, 2000. These regulations apply to either owners or operators of a combustion device used to combust commercial and industrial waste, and that meet either of the following two criteria: 1) began construction either on or after December 31, 1999; or 2) began either reconstruction or modification either on or after June 1, 2001. Commercial and industrial waste is a solid waste combusted in an enclosed device using controlled-flame combustion without energy recovery, which is a distinct operating unit of any commercial or industrial facility, including field-erected, modular, and custom-built incineration units operating with starved or excess air, or solid waste combusted in an air curtain incinerator without energy recovery that is a distinct operating unit of any commercial or industrial facility. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 60, Subpart CCCC.

This NSPS was last amended on: February 7, 2013; June 23, 2016; and April 16, 2019. The 2013 standards apply to either owners or operators of a combustion device used to combust commercial and industrial waste, and that meet either of the following two criteria: 1) began construction either on or after June 4, 2010; or 2) began reconstruction or modification either on or after August 7, 2013. The EPA later proposed to reconsider provisions of the 2013 final revisions to the NSPS for CISWI units (80 FR 3018, January 21, 2015), and took final action on June 23, 2016 (81 FR 40956). Following promulgation of the 2016 CISWI rule, the EPA proposed to clarify various issues with implementation of these standards and certain testing and monitoring issues and inconsistencies within the rules. On June 15, 2018, the EPA proposed amendments to several provisions of the 2016 CISWI rule to address these issues (83 FR 28068). These revisions were finalized on April 16, 2019 (84 FR 15846). ‘Burdens’ associated with the 2013, 2016, and 2019 standards are addressed separately under EPA ICR Number 2384.05. Due to the delay in promulgating a Federal Plan for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR 60, Subpart DDDD), this ICR continues to apply only to those existing sources that have burdens under the 2000 standards. When a Federal Plan is finalized, the CISWI units currently complying with the 2000 standards will be required to comply with the Emission Guidelines for Existing Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD), and the burden(s) associated with the 2013, 2016, and 2019 standards (EPA ICR Number 2384.05, OMB No. 2060-0662) will supersede the burden in this ICR.

In general, all NSPS 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 the NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain this file for at least two years following the date of such measurements, maintenance reports, and records. All reports required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. If there is no such delegated authority, the EPA’s regional offices can review them. All other reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the EPA’s regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator. 

The “Affected Public” are owners and operators of CISWI units that are subject to the year 2000 standards. The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal). The Federal Government’s “burden” 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 – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal). There are approximately 13 CISWI units which are owned and operated by the CISWI industry. None of the 13 facilities in the United States are owned by either state, or local, or tribal entities or by the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA enquiries.

Based on our consultations with industry representatives, there are an average of one affected facility 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 13 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.

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 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best-demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every eight years. 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, particulate matter (PM), dioxins/furans, hydrogen chloride (HCl), cadmium (Cd), lead (Pb), mercury (Hg), carbon monoxide (CO), nitrogen oxides (NOx) and sulfur dioxide (SO2) emissions from CISWI units either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart CCCC.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards 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 these emission standards. Continuous emission monitors are used to ensure compliance with these same 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 these standards are used to inform the Agency, or its delegated authority, when a source becomes subject to the requirements of these 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 that these same standards are being met. The performance test may also be observed.

The required semiannual and annual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures, and for compliance determinations.

Additionally, the EPA is requiring electronic reporting for certain notifications or reports. The EPA is requiring that owners or operators of affected sources would submit electronic copies of performance test reports and performance evaluations through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI).

CEDRI includes the Electronic Reporting Tool (ERT) software, which is used by facilities to generate electronic reports of performance tests. The EPA is also requiring that 40 CFR Part 60, Subpart CCCC performance test reports be submitted through the EPA’s ERT.

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

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

3(a) Non-duplication

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, 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 standards to implement the Federal standards, a copy of the report submitted to either the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. 

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 (87 FR 43843) on July 22, 2022. 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 these standards, 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 13 respondents will be subject to these same standards over the three-year period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Solid Waste Association of North America, at (800) 467-9262, and the National Waste and Recycling Association, at (212) 642-4980.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for 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 these standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and that 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 these standards. The 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. The 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 either 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 (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 these standards 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 CISWI units. The United States Standard Industrial Classification (SIC) codes for the respondents affected by these standards and the corresponding North American Industry Classification System (NAICS) codes are listed in the table below:

Standard (40 CFR Part 60, Subpart CCCC)	SIC Codes	NAICS Codes
Chemical Manufacturing	28	3251
Electrical Equipment, Appliance, and Component Manufacturing	36	3351
Wood Product Manufacturing	24	3212
Furniture and Related Product Manufacturing	25	3371

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC).

A source must make the following reports:

Notifications
Notification of preconstruction (prior to commencing construction) including anticipated date of initial startup	§60.2190
Notification of actual startup	§60.2195
Qualified operator deviation notification	§60.2225(a)(1)
Qualified operator deviation notification of resumed operation	§60.2225(b)

Reports
Initial performance test report	§60.2200
Annual report	§§60.2205, 60.2210
Emission limitation or operating limit deviation report	§§60.2215, 60.2220
Qualified operator deviation status report	§60.2225(a)(2)
Performance test reports and performance evaluations (electronic submission)	§§60.2235(b)(1), (2)

A source must keep the following records:

Recordkeeping
Calendar date of each record	§60.2175(a)
Records of operating parameters	§§60.2175(b), (p)
Records of occurrence and duration of malfunction(s) of the unit and corrective action(s) taken	§§60.2175(s), (u)
Records of days when deviation from operating limits have occurred, and description of corrective actions taken.	§60.2175(e)
Records of initial and annual stack tests	§60.2175(f)
Records of all documentation produced for the siting analysis	§60.2175(g)
Records of names of persons who have completed review of site-specific information and incinerator the operating procedures	§60.2175(h) §60.2095(c)
Records of persons who have completed operator training	§60.2175(i)
Records of contact information for persons who meet operator qualification criteria	§60.2175(j)
Records of monitoring device calibrations	§60.2175(k)
Records of equipment vendor specifications and related operation and maintenance requirements for the incinerator, emission controls, and monitoring equipment.	§60.2175(l)
Records of daily log of quantity and types of wastes burned.	§60.2175(n)
Records of the annual air pollution control device inspections, any required maintenance, and any repairs not completed within 10 days of an inspection	§60.2175(o)
Records should be retained for five years.	§60.2175

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.

The rule was amended to include electronic reporting provisions on June 23, 2016. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and performance evaluations and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application, rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts.

Electronic copies of records may also be maintained in order to satisfy Federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO₂.

Perform initial performance test, Reference Method 1, 3A or 3B, 5, 6 or 6C, 7 or 7E, 9, 22, 23, 26 or 26A, 29, 30B, and 321 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

The 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 standards 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. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. The 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). According to the 2000 final rule (65 FR 75348), approximately 9 percent of companies that own existing affected facilities might be classified as small businesses. Additionally, the number of existing entities has continued to decrease over time as units that commence construction after June 4, 2010, or commence either reconstruction or modification after August 7, 2013, which become subject to the 2013, 2016, and 2019 CISWI standards (EPA ICR Number 2384.05, OMB No. 2060-0662). 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 to be 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, at the end of this document, in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 neither conduct nor 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 2,800 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, Agency knowledge and experience with the NSPS 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 $157.61 ($75.05 + 110%)

Technical $123.94 ($59.02 + 110%)

Clerical $62.52 ($29.77 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.

(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 these regulations. 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)
Wet Scrubber a	$77,413	0	$0	$13,517	13	$175,721
Totals (rounded) b			$0			$176,000

^a The total O&M cost is $13,517, and includes the O&M cost of parameter monitoring equipment ($211) and the contractor labor cost associated with annual stack testing ($13,306). We estimate stack testing will require 125 contractor hours per respondent at a rate of $106.45 per hour.

^b Totals have been rounded to 3 significant digits. 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 $176,000. 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 $176,000. These are the 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. The EPA's overall compliance and enforcement program includes such activities 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 $20,200.

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

Managerial $70.56 (GS-13, Step 5, $44.10 + 60%)

Technical $52.37 (GS-12, Step 1, $32.73 + 60%)

Clerical $28.34 (GS-6, Step 3, $17.71 + 60%)

These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 13 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 13 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	13	0	0	13
2	0	13	0	0	13
3	0	13	0	0	13
Average	0	13	0	0	13

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 13.

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
Preconstruction Report	0	1	0	0
Report prior to initial startup	0	1	0	0
Notification of initial performance test	0	1	0	0
Notification of initial CMS Demonstration	0	1	0	0
Report of initial performance test	0	1	0	0
Report established values for site-specific operating parameters	0	1	0	0
Waste management plan	0	1	0	0
Annual Report a	13	1	0	13
Deviation Report b	1	2	0	2
Qualified Operator Deviation Notification b	1	1	0	1
Qualified Operator Report b	1	2	0	2
			Total	18

The number of Total Annual Responses is 18.

The total annual labor costs are $336,000. Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 at the end of this document, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 2,800 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 156 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $176,000. 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 396 labor hours at a cost of $20,200; see below in Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (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 decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This decrease in burden is not due to any program changes. Instead, the decrease is due to a decrease in the number of respondents to reflect facility closures. There is also a decrease in Capital/Startup and Operation and Maintenance costs due to a decrease in the number of sources.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 156 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-OAR-2022-0024. 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), 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. 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-OAR-2022-0024 and OMB Control Number 2060-0450 in any correspondence.

Part B of the Supporting Statement

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

Table 1: Annual Respondent Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal)

Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year	Clerical hours per year	Total cost per year ($) b
			(C=AxB)			(F=Ex0.05)	(G=Ex0.10)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c, d	16	1	16	13	208	10.4	20.8	$28,719.08
B. Required Activities
1) Initial requirements e
a) Initial stack test and report (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2)	24	1	24	0	0	0	0	$0
b) Establish and teach operator qualification course	64	1	64	0	0	0	0	$0
c) Obtain operator qualification	72	1	72	0	0	0	0	$0
d) Establish operating parameters (maximum and minimum)	160	1	160	0	0	0	0	$0
e) Continuous parameter monitoring initial costs (including by-pass stack) d, f	8	1	8	0	0	0	0	$0
f) Initial review of site-specific information	See 3B
2) Periodic requirements g
a) Annual stack test and test report (PM, HCl, and opacity)	12	1	12	13	156	7.8	15.6	$21,539.31
b) Annual refresher operator training course	12	1	12	13	156	7.8	15.6	$21,539.31
c) Annual review of site-specific information	8	1	8	13	104	5.2	10.4	$14,359.54
d) Continuous parameter monitoring (including by-pass stack) annual costs h	83	1	83	13	1079	54	107.9	$148,980.23
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Report prior to construction (includes siting analysis) e	160	1	160	0	0	0	0	$0
2) Report prior to initial start-up e, i
a) With site-specific parameter petition	6	1	6	0	0	0	0	$0
b) Without site-specific parameter petition	14	1	14	0	0	0	0	$0
3) Report of initial performance test	See 3B
4) Siting analysis for new units only (establishes values for site-specific operating parameters) e	8	1	8	0	0	0	0	$0
5) Waste management plan e	160	1	160	0	0	0	0	$0
6) Annual Report
a) Site-specific operating parameters	8	1	8	13	104	5.2	10.4	$14,359.54
b) Emissions/parameter exceedances and malfunctions j	See 3E(9)
c) Results of stack tests conducted during the year	See 3B
d) Statement of no exceedances j	8	1	8	12	96	4.8	9.6	$13,254.96
e) Documentation of use of by-pass stack	See 3B
f) Documentation for periods when all qualified operators were unavailable for more than 8 hours	8	1	8	13	104	5.2	10.4	$14,359.54
7) Status report for operators that are off-site for more than 2 weeks k	8	1	8	1	8	0.4	0.8	$1,104.58
8) Corrective action summary for operators that are off-site for more than 2 weeks k	8	2	16	1	16	0.8	1.6	$2,209.16
9) Semiannual report of emissions/parameter exceedances j	12	2	24	1	24	1.2	2.4	$3,313.74
Subtotal for Reporting Requirements					2,363			$283,739
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) Records of operating parameters	See 3B
2) Records of periods for which minimum amount of data on operating parameters were not obtained j	0.5	52	26	1	26	1.3	2.6	$3,589.89
3) Records of malfunction of the unit j	1.5	1	1.5	1	1.5	0.08	0.15	$207.11
4) Records of exceedances of operating parameters j	1.5	1	1.5	1	1.5	0.08	0.15	$207.11
5) Records of stack tests	See 3E
6) Records of siting analysis	See 3E
7) Records of persons who have reviewed operating procedures	1	1	1	13	13	0.65	1.3	$1,794.94
8) Records of persons who have completed operator training	1	1	1	13	13	0.65	1.3	$1,794.94
9) Records of persons who meet operator qualification criteria	1	1	1	13	13	0.65	1.3	$1,794.94
10) Records of monitoring device calibration	See 3B
11) Records of site-specific documentation	24	1	24	13	312	15.6	31.2	$43,078.62
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					437			$52,468
Total Labor Burden and Costs (rounded) l					2,800			$336,000
Total Capital and O&M Cost (rounded) l								$176,000
Grand Total (rounded) l								$512,000
Assumptions:
a We estimate that 13 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We assume that all respondents will have to familiarize themselves with the regulatory requirements each year.
d Cost is incurred by a facility regardless of the number of affected units at the plant.
e One-time only cost.
f Based on memorandum titled “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions," A-91-61, IV-B-66. We have assumed $500 and $300 for planning and selection, respectively. ($500 + $300)/$100.23 per hour = 8 hours.
g Annual costs are not incurred until the second year that units are in operation.
h We assume 83 technical labor hours for reporting, based on memorandum titled “Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators (MWIs) - Methodology and Assumptions," A-91-61, IV-B-66.
i We assume that new sources will petition for site-specific parameters.
j We assume that exceedances and malfunctions each will account for 10 percent of existing facilities. 10% x 13 facilities = 1 facilities. The remaining 12 facilities would submit a statement of no exceedance.
k We assume that 10 percent of facilities will not have a qualified operator available for more than two weeks at least once a year, and that two corrective action summaries will be required.
l Totals have been rounded to 3 significant figures. Totals may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NSPS for Commercial and Industrial Solid Waste Incineration (CISWI) Units (40 CFR Part 60, Subpart CCCC) (Renewal)

Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CXD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Observe initial stack tests (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, and SO2) c, d	48	1	48	0	0	0	0	$0
B. Create Information	N/A
C. Gather Information	N/A
D. Report Reviews
1) Review control plan d	8	1	8	0	0	0	0	$0
2) Review notification of final compliance d	8	1	8	0	0	0	0	$0
3) Review waste management plan d	8	1	8	0	0	0	0	$0
4) Review initial stack test report d	40	1	40	0	0	0	0	$0
5) Review annual compliance report	8	1	8	13	104	5.2	10.4	$6,108
6) Review semi-annual excess emission and parameter exceedance report	16	2	32	1	32	1.6	3.2	$1,879
7) Review status reports and corrective action summary for operators off-site	4	2	8	1	8	0.4	0.8	$470
F. Prepare annual summary report e	4	1	4	50	200	10	20	$11,746
TOTAL (rounded) f					396			$20,200
Assumptions:
a We estimate that 13 existing respondents and zero new respondents per year will be subject to the rule over the three-year period of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2021 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.
c We estimate initial stack test observations will take 48 hours per plant.
d One-time only cost.
e We assume that each state (i.e., 50 respondents) will prepare an annual summary of progress for implementing state plans.
f Totals have been rounded to 3 significant figures. Totals may not add exactly due to rounding.

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