SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Sewage
Sludge
Treatment
Plants
(
40
CFR
part
60,
subpart
O)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Sewage
Sludge
Treatment
Plants
(
40
CFR,
part
60,
subpart
O)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Sewage
Treatment
Plant
incinerators
(
40
CFR
part
60,
subpart
O)
were
promulgated
on
February
28,
1974
(
39FR9312)
and
amended
in
October
6,
1975,
November
10,
1977,
October
6,
1988,
and
October
17,
2000.
These
standards
apply
to
each
incinerator
which
combusts
wastes
containing
more
than
10
percent
sewage
sludge
(
dry
basis)
produced
by
municipal
sewage
treatment
plants
or
each
incinerator
which
charges
more
than
1000
kg
(
2205
lb.)
per
day
municipal
sewage
sludge
(
dry
basis),
and
any
facility
that
commenced
construction
or
modification
after
June
11,
1973.
Particulate
matter
(
PM)
is
the
pollutant
regulated
under
this
subpart.
The
standard
sets
an
emission
limitation
for
PM.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
60,
subpart
O.

Owners
or
operators
of
the
facilities
regulated
under
this
subpart
must
make
several
one­
time­
only
reports
and
maintain
records.
This
includes
various
notifications
and
records
from
monitoring
devices
and
facility
operations.
In
general,
these
notifications,
reports
and
records
are
required
of
all
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
records,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
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.

Approximately
54
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
there
will
be
no
new
growth
in
the
industry
over
the
next
three
years.
However,
one
additional
source
per
year
will
become
subject
to
the
standard
over
the
next
three
years
due
to
the
modification
or
reconstruction
of
an
existing
affected
facility.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
to
be
$
390,931.

In
the
development
of
the
ICR,
we
addressed
the
Office
of
Management
and
Budget
2
(
OMB)
"
Terms
of
Clearance
(
TOC)
on
the
active
ICR.
The
TOC
are
as
follows:

This
Information
Collection
Request
is
approved
for
three
years.
When
EPA
resubmits
this
ICR
for
renewal,
it
should
update
the
wage
rates
and
verify
that
they
have
been
properly
loaded
to
include
overhead,
consistent
with
current
EPA
and
OMB
guidelines.

EPA
has
addressed
the
items
of
concern
in
the
TOC
as
instructed
by
OMB
in
the
active
ICR.
See
sections
6(
b)
and
6(
c)
for
updated
labor
figures
and
attached
Tables
1
and
2
for
the
specific
calculations.

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
four
years.

In
the
Administrator's
judgment,
particulate
matter
emissions
from
sewage
sludge
treatment
plant
incinerators
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
O.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
particulate
matter
from
sewage
sludge
treatment
plant
incinerators
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulate
matter
from
sewage
sludge
treatment
plant
incinerators
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
particulate
matter
emissions
using
control
technology
and
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
3
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
records
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
being
affected
by
the
NSPS
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
(
40
CFR
part
60,
subpart
O).

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
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
a
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
(
68
FR
62289)
on
November
3,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
and
accessed
the
most
recent
data
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
United
States
Census
Bureau,
and
other
websites
covering
sewage
sludge
treatment
plants.
We
consulted
with
the
EPA's
Office
of
4
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division
and
Back
River
Waste
Water
Treatment
Plant,
Mr.
Nick
Frankos,
(
410)
396­
9814.

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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

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
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
sewage
sludge
treatment
plants.
The
United
States
Standard
Industrial
Classification
(
SIC
)
code
for
the
respondents
affected
by
the
standards
is
4952
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS
)
221320
for
Sewage
Sludge
Treatment
Plants.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
New
Source
5
Performance
Standards,
(
NSPS),
for
Sewage
Sludge
Treatment
Plants
(
40
CFR
part
60,
subpart
O).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
and
application
of
construction
or
modification.
60.07(
a)(
1)

Notification
of
anticipated
date
of
initial
startup.
60.07(
a)(
2)

Notification
of
actual
startup.
60.07(
a)(
3)

Notification
of
physical
or
operational
change
which
may
increase
the
emission
rate.
60.07(
a)(
4)

Notification
of
initial
performance
tests.
60.08(
d)

Demonstration
of
continuous
monitoring
system.
60.7(
a)(
5)

Date
upon
which
demonstration
of
continuous
monitoring
system
performance
commences.
60.07(
a)(
5)

Reports
Initial
performance
test.
60.08(
a)

Report
of
excess
emissions.
60.07(
c)
and
60.155
Owner
or
operator
of
any
multiple
hearth,
fluidized
bed,
or
electric
sludge
incinerator
shall
submit
a
semiannual
report
which
contains
the
following:
scrubber
pressure
drop
measurements,
oxygen
content,
temperatures,
rate
of
sludge
charged,
moisture
and
volatile
solids
of
daily
grab
sample
of
sludge
charged
to
the
incinerator,
and
a
record
of
control
device
operation
measurements
for
other
than
a
wet
scrubber.
60.155(
a),
60.155(
b),
and
60.155(
c)

A
source
must
keep
the
following
records:

Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.07(
b)
6
Recordkeeping
Maintain
a
file
of
all
measurements
including,
performance
test
measurements,
and
all
other
information
required
by
this
subpart
recorded
in
a
permanent
file
suitable
for
inspection.
60.07(
e)

Recording
of
daily
charging
rates
and
hours
of
operations
60.153(
a)(
1)

Install,
calibrate,
maintain
and
operate
weighing
device
for
determination
of
the
mass
of
any
municipal
solid
waste
charged
to
the
incinerator.
60.153(
a)(
3)

Install,
calibrate,
maintain
and
operate
a
monitoring
device
that
continuously
measures
and
records
the
pressure
drop
of
gas
flow
through
the
wet
scrubbing
device.
60.153(
b)(
1)

Install,
calibrate,
maintain
and
operate
a
monitoring
device
that
continuously
measures
and
records
the
oxygen
content
of
the
incinerator
exhaust
gas.
60.153(
b)(
2)

Install,
calibrate,
maintain
and
operate
temperature
measuring
devices.
The
temperature
monitoring
devices
shall
be
operated
continuously
and
data
recorded
during
all
periods
of
operation
of
the
incinerator.
60.153(
b)(
3)

Install,
calibrate,
maintain
and
operate
a
device
for
measuring
the
fuel
flow
to
the
incinerator.
The
fuel
flow
measuring
device
shall
be
operated
continuously
and
data
recorded
during
all
periods
of
operation
of
the
incinerator.
60.153(
b)(
4)

Collect
and
analyze
a
grab
sample
of
the
sludge
fed
to
the
incinerator
once
per
day.
60.153(
b)(
5)

Test
methods
and
procedures
for
performance
tests.
60.154
Install,
calibrate,
maintain,
and
operate
continuous
monitoring
system.
60.13
Owner
or
operator
of
any
multiple
hearth,
fluidized
bed,
or
electric
sludge
incinerator
subject
to
the
provisions
of
this
subpart,
shall
retain
the
following
information
and
make
it
available
for
inspection:
the
measured
pressure
drop
of
the
gas
flow
through
the
wet
scrubbing
device,
a
record
of
the
measured
oxygen
content
of
the
incinerator
exhaust
gas,
record
of
the
rate
of
sludge
charged
to
the
incinerator,
the
measured
temperatures
of
the
incinerator,
the
fuel
flow
to
the
incinerator,
and
the
total
solids
and
volatile
solids
content
of
the
sludge
charges
to
the
incinerator.
60.153(
c)(
1),
60.153(
c)(
2),
and
60.153
(
c)(
3)
7
Recordkeeping
The
owner
or
operator
of
any
sludge
incinerator
other
than
a
multiple
hearth,
fluidized
bed,
or
electric
incinerator
or
any
sludge
incinerator
equipped
with
a
control
device
other
than
a
wet
scrubber
shall
submit
for
approval
a
plan
for
monitoring
and
recording
incinerator
and
control
device
operation
parameters.
60.153(
e)

Maintain
records
for
two
years.
60.07(
f)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
daily
sampling
and
analysis
of
sludge
feed.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
a
Continuous
Monitoring
System
(
CMS)
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber.

Perform
initial
performance
test,
Reference
Method
5
and
9
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
the
purpose
of
collecting,
validating,
and
verifying
information.

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

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.
8
Respondent
Activities
Adjust
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

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

Transmit,
or
otherwise
disclose
the
information.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

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
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
9
maintained
by
the
EPA's
Office
of
Compliance.
AFS
is
the
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
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
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
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
in
Table
1:
Annual
Industry
Burden
for
NSPS
for
Sewage
Sludge
Treatment
Plants
(
40
CFR
part
60,
subpart
O).

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
burdens
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
6,214
(
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
NSPS
program,
the
previously
approved
10
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
subject
standard
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
cost
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
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/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
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)

Particulate
Matter
$
100,000
1
$
100,000
$
35,000
54
$
1,890,000
The
total
capital/
startup
costs
for
this
ICR
are
$
100,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
1,890,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).
11
The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
1,990,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

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
$
41,217.
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.02
(
GS­
13,
Step
5,
$
33.76
x
1.6)
Technical
$
40.08
(
GS­
12,
Step
1,
$
25.05
x
1.6)
Clerical
$
21.70
(
GS­
6,
Step
3,
$
13.56
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
Sewage
Sludge
Treatment
Plants,
(
40
CFR
part
60,
subpart
O).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
54
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
expected
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
12
Number
of
Respondents
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
1
54
0
1
54
2
1
54
0
1
54
3
1
54
0
1
54
Average
1
54
0
1
54
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
54.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
construction/
reconstruction
1
1
N/
A
1
Notification
of
physical
and
operational
changes
1
1
N/
A
1
Notification
of
demonstration
of
CMS
1
1
N/
A
1
Notification
of
actual
startup
1
1
N/
A
1
Notification
of
initial
performance
test
1
1
N/
A
1
Semiannual
report
of
excess
emissions
54
2
N/
A
108
Total
113
(
rounded)
13
The
number
of
Total
Annual
Responses
is
113.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
390,931.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NSPS
for
Sewage
Sludge
Treatment
Plants
(
40
CFR
part
60,
subpart
O).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
1,990,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
55
(
rounded)
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
decrease
in
the
burden
from
the
most
recently
approved
ICR
is
due
to
more
accurate
estimates
of
existing
and
anticipated
new
sources.
Our
data
indicates
that
there
are
approximately
fifty­
four
sources
with
one
additional
source
due
to
reconstruction,
compared
to
the
active
ICR
that
shows
one
hundred
and
fifty­
four
sources
with
an
additional
seven
sources
per
year.
There
are
no
new
facilities
being
constructed
at
this
time.
Reconstruction
of
facilities
is
the
only
expected
activity.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
55
hours
per
response.
Burdens
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
14
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
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
OECA­
2003­
0141,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
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
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
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
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0141
and
OMB
Control
Number
2060­
0035
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Annual
Respondent
Burden
and
Cost
­
NSPS
for
Sewage
Sludge
Treatment
Plants
(
40
CFR
part
60,
subpart
O).

Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
1bc
1
0.05
0.1
$
72.75
B.
Required
activities
Initial
performance
test
72
1
72
1bc
72
3.6
7.2
$
5,237.96
Demonstration
of
monitoring
system
Included
in
performance
test
Repeat
performance
test
72
1
72
0.2d
14.4
0.72
1.44
$
1,047.59
C.
Create
information
Included
in
3B
D.
Gather
existing
information
N/
A
E.
Write
Report
Notification
of
construction/

reconstruction
2
1
2
1bc
2
0.1
0.2
$
145.50
Notification
of
physical
and
operational
changes
2
1
2
1
e
2
0.1
0.2
$
145.50
Notification
of
demonstration
of
CMS
40
1
40
1bc
40
2
4
$
1,037.38
16
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
Notification
of
actual
startup
2
1
2
1bc
2
0.1
0.2
$
145.50
Notification
of
initial
performance
test
2
1
2
1bc
2
0.1
0.2
$
145.50
Performance
test
report
Included
in
3B
Semiannual
reports
of
excess
emissions
40f
2
80
54g
4,320
216
432
$
314,277.84
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
4E
B.
Plan
activities
Included
in
4E
C.
Implement
activities
Included
in
4E
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
a.
Record
of
daily
production
rate
and
hours
of
operation
8h
1
8
54
g
432
21.6
43.2
$
31,427.78
b.
Records
of
startup,

shutdown
and
malfunction
8
1
8
54
g
432
21.6
43.2
$
31,427.78
c.
Records
of
performance
test
data
80i
1
80
1bc
80
4
8
$
5,819.96
Subtotal
Labor
Burden
5,404.8
269.97
539.94
$
390,931.04
17
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
6,214
$
390,931
Assumptions:

a
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."

b
Assume
that
there
will
be
one
new,
modified
or
reconstructed
facility
constructed
for
the
next
three
years.

c
Assume
that
this
is
a
one­
time­
only
cost.

d
Assume
that
20
percent
would
have
to
repeat
the
performance
testing
due
to
failure.

e
Assume
that
one
facility
will
have
a
physical
or
operational
change.

f
Assume
that
it
will
take
forty
hours
to
write
semiannual
reports.

g
Assume
that
there
are
fifty­
four
sources
subject
to
this
rule.

h
Assume
that
it
will
take
eight
hours
per
year
to
record
daily
gathering
of
monitoring
data
(
which
have
been
automatically
recorded).

i
Assume
that
it
will
take
eighty
hours
per
year
to
record
performance
test
data.
18
Table
2:
Average
Annual
EPA
Burden
­
NSPS
for
Sewage
Sludge
Treatment
Plants
(
40
CFR
part
60,
subpart
O)

Burden
Item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
a
Costs,

Per
Year
Initial
Performance
Test
24
1
24
1bc
24
1.2
2.4
$
1,078.82
Repeat
initial
performance
test
1.
Retesting
preparation
24
0.2d
4.8
1bc
4.8
0.24
0.48
$
215.76
Report
Review
Notification
of
construction/

reconstruction
2
1
2
1bc
2
0.1
0.2
$
89.90
Notification
of
Physical
and
operational
changes
2
1
2
1
e
2
0.1
0.2
$
89.90
Notification
of
actual
startup
0.5
1
0.5
1bc
0.5
0.025
0.05
$
22.48
Initial
test
0.5
1
0.5
1bc
0.5
0.025
0.05
$
22.48
Repeat
performance
test
8
1
8
1bc
8
0.4
0.8
$
359.61
Semiannual
reports
8f
2
16
54
g
864
43.2
86.4
$
38,837.66
Subtotal
905.8
45.29
90.58
$
40,716.61
Travel
Expenses
(
1
person
x
1
plant/
yr
x
2
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x1round
trips/
yr)
=
$
500
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
1,042
$
41,217
Assumptions:

a
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
54.02
for
Managerial
(
GS­
13,
Step
5,
$
33.76
x
1.6),
$
40.08
for
Technical
(
GS­
12,
Step
1,
$
25.05
x
1.6)
and
$
21.70
Clerical
(
GS­
6,
Step
3,
$
13.56
x
1.6).
These
rates
are
from
19
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b
Assume
that
there
will
be
one
new,
modified
or
reconstructed
facility
constructed
over
the
next
three
years.

c
Assume
that
this
is
a
one­
time­
only
cost.

d
Assume
that
20
percent
would
have
to
repeat
the
performance
testing
due
to
failure.

e
Assume
that
one
facility
will
have
a
physical
or
operational
change.

f
Assume
that
it
will
take
eight
hours
to
review
semiannual
reports.

g
Assume
that
there
are
fifty­
four
sources
subject
to
this
rule.
20
