Supporting Statement 

ENVIRONMENTAL PROTECTION AGENCY 

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), 

EPA ICR Number 1063.11, OMB Control Number 2060-0035

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Sewage Sludge 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 this regulation.

Approximately 112 facilities with 218 units are currently subject to the
standard. It is estimated that two new units will be built over the next
five years or 1.2 additional sources will become subject to the
regulation over the next three years.  The average annual cost to
industry over the next three years of this Information Collection
Request (ICR) is estimated to be $1,178,948 in labor, and $3,960,000 in
annualized capital/startup costs and operating & maintenance (O&M).

OMB approved the current 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 the Administrator’s judgment, particulate matter emissions from
sewage sludge treatment plant incinerators either 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 recordkeeping and reporting requirements in the standard ensures
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard(s).
Continuous emission monitors are used to ensure compliance with the
standard(s) at all times. The notifications required in the standard(s)
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 the standard(s) are
being met.  The performance test may also be observed.

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

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

The requested recordkeeping and reporting are required under 40 CFR part
60, subpart O.

3(a)  Non-duplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or 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 July 8, 2009 (74 FR 32580).  No
comments were received on the burden published in the Federal Register.

 

3(c)  Consultations

The Agency based the number of sources for this ICR on estimates in the
upcoming NSPS/Emission Guidelines (EG) for Sewage Sludge Incinerators.
The Agency has consulted with the National Association of Clean Water
Agencies to update the inventory of facilities and sources and refine
the inventory further based on new information collected from the ICR,
permits, states, and state public databases.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.  In this case, no comments were received.
 

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, part 2, subpart B -
Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/NAIC 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 NAICS (The North American Industry
Classification System) 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:

Notifications and Reports



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)





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

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. 

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
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 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 maintained by the EPA’s Office of Compliance.  AFS is
EPA’s database for the collection, maintenance and retrieval of
compliance data for over 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

There are no small businesses affected by this regulation at present,
and no small businesses are expected to become subject to the regulation
in the next three years. (64 FR 72057, December 23, 1999).

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost for NSPS for Sewage Sludge Treatment Plants (40 CFR part 60,
subpart O) (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 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 12,464
(Total Labor Hours from Table 1).  The recordkeeping hours, shown in
Table 1, are 2,097.6 and the reporting requirement hours, also shown in
Table 1, are 10,366.3.  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	$114.49 ($54.52 + 110%)   

Technical	$98.20 ($46.76 + 110%)

Clerical	$48.53 ($23.11 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2009, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

(ii)  Estimating Capital/Startup and 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	

0.4	

$40,000	

$35,000	

112	

$3,920,000

 

The total capital/startup costs for this ICR are $40,000.  This is the
total of column D in the above table.  The total operating and
maintenance (O&M) costs for this ICR are $3,920,000.  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 $3,960,000.  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 $94,999.  Details upon which this estimate is based
appear below in Table 2: Annual Agency Burden and Cost for NSPS for
Sewage Sludge Treatment Plant Incinerators (40 CFR part 60, subpart O)
(Renewal).

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

Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 % to account for the benefit packages available to
government employees.  Details upon which this estimate is based appear
below in Table 2: Annual Agency Burden and Cost for NSPS for Sewage
Sludge Treatment Plants (40 CFR part 60, subpart O) (Renewal).

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 112 existing
facilities 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	

0.4	

112	

0	

0.4	

112



2	

0.4	

112	

0	

0.4	

112



3	

0.4	

112	

0	

0.4	

112



Average	

0.4	

112	

0	

0.4	

112

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 112.  

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	

0.4	

1	

N/A	

0.4



Notification of physical and operational changes	

0.4	

1	

N/A	

0.4



Notification of demonstration of CMS	

0.4	

1	

N/A	

0.4



Notification of actual startup	

0.4	

1	

N/A	

0.4



Notification of initial performance test	

0.4	

1	

N/A	

0.4



Semiannual report of excess emissions	

112	

2	

N/A	

224



	

Total	

226 (rounded)



The number of Total Annual Responses is 226.  

The total annual labor costs are $1,178,948.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost for NSPS for Sewage Sludge Treatment Plants (40 CFR part 60,
subpart O) (Renewal).  

Note that the total annual capital and O&M costs to the regulated entity
are $3,960,000. 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 detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2 below,
respectively, and summarized below.  

(i) Respondent Tally

The total annual labor hours are 12,464. Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost for NSPS for Sewage Sludge Treatment Plants (40 CFR part 60,
subpart O) (Renewal).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 55 hours (rounded) per response.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 2,097 labor hours at a cost of $94,999.  See below Table
2: Annual Agency Burden and Cost for NSPS for Sewage Sludge Treatment
Plants (40 CFR part 60, subpart O) (Renewal).

6(f)  Reasons for Change in Burden

There is an increase in the total estimated burden as currently
identified in the OMB Inventory of Approved Burdens which is due to more
accurate estimates of existing sources.  The number of existing
facilities changed from 54 to 112 and increased the number of responses,
burden hours, labor costs, and O&M costs.  A reduction in
capital/start-up costs occurred due to the decrease of anticipated new
sources which declined from 1 to 0.4 new sources per year. 

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 55 hours per response (rounded). 
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-2009-0413. 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-2009-0413 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.

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