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

OMB: 2060-0035

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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


The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the AFS (Air Facility System) which is operated and maintained by EPA's Office of Compliance. AFS is EPAs database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 54 respondents will be subject to the standard over the three year period covered by this ICR.


Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes.


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 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.

File Typeapplication/msword
File TitleSupporting Statement for NSPS for Sewage Sludge Treatment Plants
AuthorJO'Neil
Last Modified Byjschae02
File Modified2007-08-29
File Created2007-08-29

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