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 (39 FR 9312) and amended on 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 $392,804 in labor, and $1,990,000 in annualized capital/startup costs
and operating & maintenance (O&M).

The Office of Management and Budget (OMB) approved the current
Information Collection Request (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 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
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 on October 5, 2006 (71 FR 58853). 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

For this ICR renewal, we referenced the burden estimates from the most
recent ICR renewal and accessed the data available on the AIRA Facility
Subsystem (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 EPAs Office of Air Quality Planning and Standards, Information
Transfer, the Program Integration Division and Waste Water Treatment
Plant representatives.

It is our policy to carefully review any comments received since the
last ICR renewal including those submitted in response to the first
Federal Register notice and respond appropriately; 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 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 (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

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 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.	

60.7(a)



Notification of anticipated date of initial startup.	

60.7(a)



Notification of actual startup.	

60.7(a)



Notification of physical or operational change which may increase the
emission rate.	

60.7(a)



Notification of initial performance tests.	

60.8(d)



Demonstration of continuous monitoring system.	

60.7(a)



Date upon which demonstration of continuous monitoring system
performance commences.	

60.7(a)





Reports	

Standard Citation by Section



Initial performance test.	

60.8(a)



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.	

60.7(b)



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.	

60.7(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)



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.	

60.7(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.



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 AIRS Facility Subsystem (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 sources 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 maintained by the EPA's Office of Compliance.  AFS is the
EPAs 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 Respondent Burden and Cost,
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 6,209
(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 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 Operating 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. Operating and Maintenance (O&M) Costs

Capital/Startup vs. Operating 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)



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.  The total operating and
maintenance (O&M) costs for this ICR are $1,890,000.  This is the total
of column G.

The total respondent costs 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. All costs are considered 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 $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).

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 	





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.  

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)



The number of Total Annual Responses is 113.  The total annual labor
costs are $392,804.  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.
These costs are detailed in Section 6(b)(iii), Capital/Startup vs.
Operating 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 is estimated to average 55
(rounded) hours per response.

6(f)  Reasons for Change in Burden

There was a small 5.4 hour decrease in estimated burden due to the
correction of a mathematical error on the estimated number of technical
hours.  There was a slight increase in labor burden to correct a
mathematical error on the burden line item for “3.E. Notification of
demonstration of CMS.”

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 55 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’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
EPA-HQ-OECA-2006-0711. 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
Enforcement and Compliance Docket and Information 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 Office for EPA. Please include
the EPA Docket ID Number EPA-HQ-OECA-2006-0711 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.

Table 1.  Annual Respondent Burden and Cost:

NSPS for Sewage Sludge Treatment Plants (40 CFR part 60, subpart O)

	Burden item	

	(A)

Technical Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year 	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours per

year

(Ex0.05)	

(G)

Clerical

person-

hours 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	

1e	

2	

0.1	

0.2	

$145.50



Notification of demonstration of CMS	

40	

1	

40	

1bc	

40	

2	

4	

$2909.98



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



Subtotal Reporting Labor Burden and Cost



	

5,123.71

	

$324,129.12



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	

54g	

432	

21.6	

43.2	

$31,427.78



b. Records of startup, shutdown and malfunction 	

8

	

1	

8	

54g	

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 Recordkeeping Labor Burden and Cost	

	

	

	

	

1085.60	

$68,675.84



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

6,209	

$392,804





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.

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

Occurrence	

(B)   

Number  of

Occurrences

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	

1e	

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	

54g	

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 for Clerical
(GS-6, Step 3, $13.56 x 1.6).  These rates are from 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.

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