2369ss01

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NSPS for Sewage Sludge Incinerators (40 CFR part 60, subpart LLLL) (Proposed Rule)

OMB: 2060-0658

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SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
Standards of Performance for New Stationary Sources:
Sewage Sludge Incineration (SSI) Units (Subpart LLLL)
1.

IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection
“Standards of Performance for New Stationary Sources: Sewage Sludge Incineration
(SSI) Units (Subpart LLLL).”

1(b) Characterization of Information Collection
This supporting statement addresses information collection activities imposed by the
Standards of Performance for New Stationary Sources: Sewage Sludge Incineration (SSI) Units
Subpart LLLL. The new source performance standards (NSPS) fulfill the requirements of
sections 111 and 129 of the Clean Air Act (CAA), which require EPA to promulgate NSPS for
solid waste incineration units.
The use of the term "Designated Administrator" throughout this document refers to the
U.S. EPA Administrator or a delegated authority such as a state agency. The term
"Administrator" alone refers to the U.S. EPA Administrator.
The information collection activities required by the NSPS include: siting requirements,
operator training and qualification requirements, testing, monitoring and reporting requirements,
one-time and periodic reports, and the maintenance of records. These activities will enable the
Designated Administrator to determine initial compliance with the emission limits for the
regulated pollutants, monitor compliance with operating parameters, and ensure that facilities
conduct the proper planning and operator training. We realize that some facilities may not incur
these costs within the first three years, and may incur them during the fourth or fifth year instead.
Therefore, this information collection request (ICR) presents a conservatively high burden
estimate for the initial three years following promulgation of the proposed emission guidelines.

This ICR presents the burden to respondents and the Designated Administrator (State or
Federal Government) that will be imposed by the plans developed to implement the standards of
performance for new stationary sources. Respondents are owners or operators of new or
modified SSI units.
The requirements described below are the minimum requirements established by the
standards of performance for new stationary sources. Although the Designated Administrator
may choose to impose more stringent requirements, it is assumed for this burden estimate that the
implemented plans mirror the NSPS.
Over the next three years, two respondents will be subject to this standard; two facilities
will have new or modified sewage sludge incinerators and will thus have to meet NSPS guidelines.
The cost of this Information Collection Request (ICR), based on these 2 facilities, will be
$960,000.
The burden to the “Affected Public” for each SSI may be found in Tables 1 - 4 in
Attachment 2. The burden to the “Designated Administrator” is attributed entirely to work
performed by federal employees or government contractors; this burden may be found in Tables 5
- 8 of Attachment 3.

NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection
The EPA is required under sections 111 and 129 of the CAA to establish standards of
performance for new stationary sources that reflect the maximum achievable control technology
(MACT) for achieving continuous emission reductions:

CAA section 129(a)(1) states:
Standards applicable to solid waste incinerator units promulgated under section 111 and
this section shall reflect the maximum degree of reduction in emissions of air pollutants
listed under section (a)(4) that the Administrator, taking into consideration the cost of
achieving such emission reduction, and any non-air quality health and environmental
impacts and energy requirements, determines is achievable for new or existing units in
each category.
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CAA section 111(e) further states:
After the effective date of standards of performance promulgated under this section, it
shall be unlawful for any owner or operator of any new source to operate such source in
violation of any standards of performance applicable to such source.
2(b) Practical Utility/Users of the Data
The information will be used by Designated Administrators' enforcement personnel to
ensure that the requirements of the State (or Federal) plan are being implemented and are
complied with on a continuous basis. Specifically, the information will be used by the Designated
Administrator to: (1) identify new, modified, and reconstructed sources subject to the NSPS;
(2) ensure that the NSPS is being properly applied; (3) ensure that the emission limits are being
complied with; and (4) ensure, on a continuous basis, that the operating limits established during
the initial performance test are not exceeded.
In addition, records and reports are necessary to enable the Designated Administrator to
identify SSI facilities that may not be in compliance with the NSPS. Based on reported
information, the Designated Administrator will decide which facilities should be inspected and
what records or units should be inspected at the facilities. The records that SSI facilities maintain
will indicate to the Designated Administrator whether facility personnel are properly operating
and maintaining the incinerator and control equipment and whether facility personnel have met the
qualification requirements.

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA

The requested recordkeeping and reporting will be required under (40 CFR part 60,
subpart LLLL).

3(a) Nonduplication
The information collected pursuant to the NSPS consists primarily of a siting analysis,
operator training, emissions testing, and monitoring of operating parameters. This information

collection amends the information collection requirements currently collected for SSI units by
EPA or any other Federal agency.
In more than 95 percent of the cases, the enforcement of NSPS has been delegated to
State air pollution control agencies. In such cases, the actual emission data reports required by
the NSPS will be submitted to the appropriate State agency, and not directly to EPA. Thus, there
is minimal possibility for the submittal of duplicate information to State agencies and EPA. In the
few cases where State agencies have not requested delegation of NSPS enforcement, yet still
require information from the facility, the facility owner or operator may submit a copy of the State
or local reports to EPA in lieu of the report required by the NSPS, as specified in the General
Provisions of 40 CFR part 60.

3(b) Public notice prior to ICR submission to OMB
A public notice of this collection is being provided in the Federal Register notice of
proposed rulemaking published for the emissions guidelines.

3(c) Consultations
The public will have the opportunity to review and comment on the proposed NSPS and
the ICR during the specified comment period.

3(d) Effects of Less Frequent Data Collection
The NSPS require initial and annual performance tests for eight pollutants and opacity,
continuous CO emissions monitoring, continuous operating parameter monitoring, annual
operator training, annual control device inspections, and annual reporting (semiannual deviation
reports are required if any of the emission limits or operating limits are exceeded). The frequency
of these activities was chosen by EPA as the period that will provide an adequate margin of
assurance that affected facilities will not operate for extended periods in violation of the NSPS.
The annual performance testing will ensure that, on an ongoing basis, the air pollution
control device is operating properly and its performance has not deteriorated. The NSPS allows
the owner or operator to skip two annual tests for particulate matter, hydrogen chloride, mercury,

nitrogen oxides, sulfur dioxide, cadmium, or lead emissions if all performance tests over the
previous three years show compliance with the emission limit.
During the initial performance test for particulate matter (PM), dioxins/furans, opacity,
hydrochloric acid (HCl), cadmium (Cd), lead (Pb), mercury (Hg), nitrogen oxides (NOx) and
sulfur dioxide (SO2) the owner or operator must establish maximum or minimum values for each
operating parameter. Thereafter, the owner or operator must conduct annual performance tests
for the eight previously listed pollutants and opacity, and continuously monitor CO emissions and
the operating parameters.
Although continuous monitoring of operating parameters cannot provide a direct
measurement of emissions, it is less expensive than CEMS, and the information provided can be
used to ensure that the incinerator and associated air pollution control equipment are operating
properly. This information assures EPA and the public that the reductions envisioned by the
regulations are being achieved. Less frequent monitoring would not ensure continuous
compliance.
The proposed NSPS includes initial and annual operator training requirements for SSI unit
operators. (The NSPS requires at least one qualified operator or supervisor per facility.) The
annual training requirements include annual refresher training to maintain operator qualification
and an annual review of site-specific documentation. The way in which an incinerator is operated
has a significant impact on the emissions from that incinerator. The annual operator training is
essential to ensure that the incinerator is being operated properly. The NSPS contains flexibility
in the operator training by allowing the use of State-approved training and qualification programs.
Annual reporting allows the submittal of required information and data parameters so that
any potential problems can be identified in a timely fashion. A semiannual deviation report is
required for deviations from the operating limits and the emission limits so that the Designated
Administrator can ensure that rapid corrective action is being taken.

3(e) General Guidelines
With the exception of requiring records to be maintained for more than 3 years, none of
the guidelines in 5 CFR 1320.5 are being exceeded. The NSPS requires all records to be
maintained by the source for a period of 5 years. In 40 CFR part 63, subpart A, "General
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Provisions for National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source
Categories," owners or operators of facilities are required to keep and maintain records for a
period of 5 years. Records must be kept on file for use, if needed, by the regulating authority to
ensure that the plant personnel are operating and maintaining control equipment properly.
Furthermore, CAA section 129 requires all SSI units to obtain title V operating permits under 40
CFR part 70 or 71 permit programs. The title V permit programs also require records to be
retained for 5 years. The NSPS allows files to be kept in paper or electronic format and must be
available onsite.

3(f) Confidentiality
All information submitted to EPA for which a claim of confidentiality is made will be
safeguarded according to EPA policies set forth in title 40, chapter 1, part 2, subpart B,
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976,
amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR
17674, March 23, 1979).

3(g) Sensitive Questions
The reporting or recordkeeping requirements in the standard do not include sensitive
questions.

THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes
Respondents would be owners or operators of SSI units for which construction
commences after the date of proposal publication in the Federal Register or for which
modification commences 6 months (or later) after promulgation of the final NSPS. These
standards affect any industry using a sewage sludge incinerator as defined in the regulation. This
includes North American Industry Classification System (NAICS) Code 221 (Sewage Treatment
Facilities and Water Treatment Plants), among others.
Based on the assumed distribution of new or modified facilities with affected sewage
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sludge incinerators, there are 2 facilities which will be affected. Of these, 100 percent are assumed to
be located in the public sector.

4(b) Information Requested
(i) Data Items
Attachment 1, Source Data and Information Requirements, and Tables 1 - 4 of
Attachment 2 present a summary of the recordkeeping and reporting requirements of this
regulation.

(ii) Respondent Activities
The respondent activities required by the standards are provided under the first column of
Tables 1 through 3 of Attachment 2, introduced in section 6(a). All burden items are included in
these tables.

(iii) Summary of Requirements
The information collection activities in this ICR include the following: preparation of a
siting analysis, performance tests, operating parameter monitoring, operator training, one-time
and periodic reports, and the maintenance of records. Some information collection activities
included in the NSPS may occur within the first three years, and are presented in this burden
estimate, but may not occur until 4 or 5 years following promulgation of the proposed standards
for some affected sources. To be conservative in our estimate, the burden for these items is
included in this ICR.
The NSPS requires an initial performance test for PM, dioxins/furans, opacity, HCl, Cd,
Pb, Hg, NOx, and SO2. During the initial performance test, the owner or operator must establish
limits for each operating parameter. Thereafter, the owner or operator must conduct annual
performance tests and continuously monitor the operating parameters; it also requires continuous
monitoring of CO emissions. The NSPS allows the owner or operator to skip two annual
performance tests for PM, HCl, mercury, NOx, SO2, cadmium, or lead emissions if all
performance tests over the three previous years show compliance with the emission limit.

To ensure the proper operation of the incinerator, the NSPS requires that each facility
establish and maintain at least one qualified SSI unit operator or supervisor. The operator
qualification process includes training, an exam, and review of site-specific materials. The
operator qualification requirements allow the flexibility to use State-approved training and
qualification programs. To maintain qualification the operators or supervisors must attend an
annual refresher course and review site-specific materials annually.
Prior to commencing construction, the owner or operator must submit a report that
includes a statement of intent to construct, the anticipated date of commencement of construction,
the siting analysis, and the anticipated date of initial start-up. The siting analysis considers air
pollution control alternatives that minimize, on a site-specific basis, potential risks to public health
or the environment.
Prior to initial startup, the owner or operator must submit a report that documents the
maximum design waste burning capacity, the anticipated maximum charge rate, and any petitions
for site-specific operating parameters.
Following the initial performance test, the owner or operator must submit a report that
documents the results of the performance test and the values for the facility’s operating limits.
An annual report is required that documents: the values for the operating limits; any
deviations or malfunctions; the results of any performance tests; if no deviations occurred, a
statement that no deviations occurred; and documentation of periods when all qualified operators
were unavailable for more than 8 hours.
If the operating limits or emission limitations are exceeded, the owner or operator must
submit a deviation report that provides details on the deviation.
As specified in the NSPS, owners or operators of SSI units are required to keep records
of certain parameters and information for a period of 5 years. Owners or operators are required
to maintain records of the initial performance test, annual performance tests, and any subsequent
performance tests. Owners or operators must also maintain records of the monitoring data for the
operating parameters, and records of monitoring device calibration.
Records must be maintained for any deviations from the operating limits, and days for
which the minimum amount of operating parameter monitoring data were not obtained.

Owners or operators must maintain the names of persons who have completed the review
of site-specific information and who have met the operator qualification requirements. Records
must also be maintained of all documentation for the siting analysis and site-specific
documentation.
All reports are to be submitted to the Designated Administrator. The information will be
used to determine that all sources subject to the emission guidelines are achieving the
requirements.

THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION,
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities
A list of Agency activities is provided in section 6(c) and in Tables 5 through 8 of
Attachment 3.

5(b) Collection Methodology and Management.
This collection of information does not require the use of automated collection techniques
because of the relatively small number of respondents affected. See section 5(d) Collection
Schedule.

5(c) Small Entity Flexibility
There are no small entities (i.e., small businesses) affected by this regulation.
The NSPS does not contain any provisions reserved exclusively for the benefit of small
entities. However, the NSPS does contain provisions that reduce the impact on all regulated
entities, which would include any small entities. The owner or operator is allowed to skip two
annual performance tests for particulate matter, hydrogen chloride, mercury, nitrogen oxides,
sulfur dioxide, cadmium, or lead emissions if all performance tests over the previous three years
show compliance. Deviation reports are required only if there is a deviation, otherwise reporting
is annual, and operating parameter monitoring is required instead of continuous emissions
monitoring systems (CEMS), except for CO.
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5(d) Collection Schedule
In the first three years following promulgation of the NSPS, owners or operators would
perform the following one-time information collection activities: reading the NSPS, notification of
intent to construct (includes a study addressing siting requirements), report prior to initial startup, initial performance tests (PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, NOx, and SO2), initial
operator training and qualification, and report following initial performance test (includes
operating parameter values). The data will be entered into the Aerometric Information Retrieval
System (AIRS), operated and maintained by EPA’s Office of Air Quality Planning and Standards.
Annual performance tests are required for the pollutants along with continuous parameter
monitoring. An annual operator training refresher course, site-specific information review, and
also an annual control device inspection is required.
An annual report is required that includes compliance data on the operating limits,
performance test results, identification of deviations and malfunctions, and documentation of
periods when all qualified operators were unavailable for more than 8 hours.
Additionally, if the operating limits or emission limits are exceeded, the owner or operator
must submit a deviation report that provides details on the deviation. Information obtained from
annual compliance reports will be published and distributed through the EPA compliance data
system (CDS). Data obtained during periodic visits by EPA personnel from records maintained
by the respondents will be tabulated and published for internal EPA use in compliance and
enforcement programs.

ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 1 through 4 of Attachment 2 document the computation of individual burdens and
non-labor costs for the recordkeeping and reporting requirements applicable to the industry for
each year for the subpart included in this ICR. The individual burdens are expressed under
standardized headings believed to be consistent with the concept of burden under the Paperwork
Reduction Act. Where appropriate, specific tasks and major assumptions have been identified.
Responses to this information collection are mandatory. Table 8 of Attachment 2 presents a
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summary of the agency burden.

6(a) Estimating Respondent Burden
The baseline population of 2 new or modified SSI units is based upon past growth in
consideration with the requirements of the NSPS rule.
The average annual burden to industry over the next three years from these recordkeeping
and reporting requirements is estimated to be 518 hours. The average annual recordkeeping
hours shown in Tables 1 - 3 of Attachment 2 are 43 and the reporting requirement hours shown
are 475.

6(b) Estimating Respondent Costs
The information collection activities for sources subject to these requirements are
presented in Tables 1 through 3 of Attachment 2. The total cost for each respondent activity
includes labor costs, capital/startup costs, and operating and maintenance (O&M) costs.

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

Managerial

$92.77 ($43.44 + 110%)*1.017

Technical

$57.22 ($26.79 + 110%)*1.017

Clerical

$35.24 ($16.50 + 110%)*1.017

These rates are taken from the Bureau of Labor Statistics, Occupational Employment Statistics,
May 2009 National Industry-Specific Occupational Employment and Wage Estimates for NAICS
999300 - Local Government categories. The occupational categories that are the most similar to
personnel operating SSI unit operations are assumed to be Engineering Technicians, except
Drafters, all other (17-3029), General and Operations Managers (11-1021), and Secretaries,
except Legal, Medical, and Executive (43-6014). The labor rates are adjusted with an average
fringe benefit and overhead rate addition of 110 percent times the base rate to account for paid
leave, insurance, etc. Since the labor rates are from May 2009, an Employment Cost Index (ECI)
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factor of 1.017 was also used to adjust the rates to March 2010 to give a current rate. Therefore,
the total loaded wage rates are calculated by the following equation:

(Base labor rate + (Base labor rate x 1.10))*ECI factor = Loaded labor rate

For emission testing labor rates, a nominal labor rate of $80.00 per hour is used. This
labor rate reflects the current loaded labor rate for emission testing contractors and includes fringe
benefits and overhead, as well as the additional equipment costs needed to perform emission tests
and analyze gas samples.

(ii) Estimating Capital/Start-up and Operation and Maintenance Costs
The capital costs associated with the proposed emission guidelines include a file cabinet
for storing copies of records and reports, and monitoring system initial costs; one time costs when
a facility becomes subject to the regulation. The annual operation and maintenance costs are the
ongoing costs to maintain the monitors, conduct initial and subsequent annual testing, and other
costs such as photocopying and postage. As discussed earlier, we have estimated the burden if
these occurred within the first three years, but realize that some facilities may incur these costs
within years 4 or 5.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
Below are the estimated capital and startup costs and O&M costs for the affected units for
the first 3 years after promulgation.

Capital/Startup vs. Operation and Maintenance (O&M) Costs

SSI Units

(B)
Number of
Respondents
(facilities)

$454,000

(D)
Total Annualized
Capital/Start-up
and O&M over 3
years
$874,000

The total capital/startup costs for this ICR are $454,000.
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(E)
Average Annual
Capital/Startup
and O&M Costs
$291,000

The total annualized capital/startup and O&M costs for this ICR are $874,000, or an
average of $291,000 per year. These are recordkeeping costs.

6(c) Estimating Agency Burden and Cost
Because the information collection requirements were developed as an incidental part of
standards development, no costs can be attributed to the development of the additional
information collection requirements. Because reporting and recordkeeping requirements on the
part of the respondents are required under sections 111 and 129 of the Act, no operational costs
would be incurred by the Federal Government. Publication and distribution of the information are
part of the AIRS Facility subsystem, with the result that no Federal costs can be directly attributed
to the ICR. Examination of records to be maintained by the respondents would occur incidentally
as part of the periodic inspection of sources that is part of the Designated Administrator’s overall
compliance and enforcement program and, therefore, could not be attributable to the ICR. The
only costs that the Implementing Agency would incur in the first three years are: reading and
understanding the rule and the preparing of an annual report summarizing progress in
implementing State plans and the compliance status of all the affected facilities. However, to be
conservative in our estimate, we have estimated the burden as if the costs to the Implementing
Agency for initial and ongoing compliance activities are also accounted for.
The average annual Agency cost during the three years of the ICR is estimated to be
$7,300.
This cost is based on the average hourly labor rates 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 percent to account for
overhead and fringe benefit costs. Details on the line item estimates used to calculate these
burdens are presented in Tables 5 through 8 of Attachment 3.
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6(d) Estimating the Respondent Universe and Total Burden Costs
The total number of respondents is also referred to as the respondent universe. The
respondent universe for this ICR is based upon past growth in consideration with the
requirements of the NSPS rule. Industry burden is calculated based on the number of units and
the anticipated controls and monitoring that each unit will most likely utilize to comply with the
proposed NSPS.
Additional estimates regarding the respondent universe are included in the industry burden
determination. The EPA estimates that 2 respondents (facilities) will read the rule in year 1,
submit a report for construction including siting analysis, and will submit a control plan. We have
also included the burden associated with initial monitoring in the year 1 estimates. In years 2 and
3, the 2 respondents incur the annual burden associated with the NSPS, such as annual testing and
monitoring system operation and maintenance.

Total Annual Responses
(B)
Number of
Respondents (facilities)

(D)
Average Annual
Number of Responses

SSI Units

The number of average annual responses is 20.

6(e) Bottom Line Burden Hours and Cost Tables
(i) The Respondent Tally
A breakdown for each of the collection, reporting, and recordkeeping activities required
by the NSPS is presented in Tables 1 through 4 of Attachment 2. Tables 1, 2, and 3 show the
costs for SSI units in years 1, 2, and 3. Table 4 summarizes the costs for the three year period.
The estimate of total annual hours requested from the respondents was based on the assumptions
outlined in section 6(d) of this ICR. The respondent burden is estimated for the first 3 years after
adoption of these guidelines by totaling the hours per year for technical, managerial, and clerical
staff at the plant. This total was then divided by 3 to arrive at the annualized burden (see
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Table 4). A similar approach was taken for estimating annual labor costs. For the first three
years after the adoption of the NSPS, it is estimated that industry would expend 518 hours
annually at a cost of $29,000 per year to meet the monitoring, recordkeeping, and reporting
requirements. The annual non-labor costs are estimated at $291,000, which include the annual
costs associated with the monitoring system and initial and annual performance testing.

(ii) The Designated Administrator
The bottom line Designated Administrator burden hours and costs, presented in Tables 5
through 7 of Attachment 3, were calculated by totaling the hours per year for technical,
managerial, and clerical staff, and by totaling the cost column. Table 8 of Attachment 3
summarizes the annual agency burden for each of the first three years and calculates the average
annual burden by dividing the three year total by three. The estimated average annual burden over
the first 3 years for the Designated Administrator would be 156 hours at a cost of $7,300 per
year.

(iii) Variations in the annual bottom line
The total respondent costs for years 1, 2, and 3 are $358,000, $302,000, and $302,000.
The corresponding total respondent hours over these periods is 933, 310, and 310 (see Tables 1
through 4 of Attachment 2). Activities include reading and understanding the rule, developing a
control plan, and developing a construction plan including siting analysis. We have also estimated
the burden of the rule to occur within the first three years. These include initial and annual
performance tests, operator training and qualification, setting and monitoring of operating
parameter values, and reporting and recordkeeping for these activities. We realize, however, that
some of these activities will not occur until years 4 or 5 for some sources. Therefore, the
respondent burden for years 1 through 3 may be conservatively high.
During the first 3 years, the Designated Administrators will be reviewing the regulation,
reviewing the control plans, observing initial stack tests, reviewing initial test reports, and
preparing annual summary reports. In years 1, 2, and 3, the Designated Administrators will
expend 258, 106, and 106 total hours in labor, respectively. The corresponding costs for each
year are $12,500, $4,800, and $4,800 (see Tables 5 through 8 of Attachment 3).
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6(f) Reasons for change in burden
This is the first submittal of this burden estimate; therefore, this section is not applicable.

6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is
estimated to be 26 hours per response. Burden means 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 currently valid OMB control number. The OMB
control numbers for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the use
of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID Number EPA-HQ-OAR-2009-0559. 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
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number for the docket center is (202) 566-1927. Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID
Number EPA-HQ-OAR-2009-0559 in any correspondence.

PART B OF THE SUPPORTING STATEMENT

This section is not applicable because statistical methods are not used in data collection associated
with this regulation.

ATTACHMENT 1
SOURCE DATA AND INFORMATION REQUIREMENTS
40 CFR
60 Subpart LLLL

Requirement
RECORDKEEPING
5-year retention of records.

60.4910

Calendar date of each record.

60.4910(a)

Records of documentation of siting requirements.

60.4910(b)

Records of site-specific information and incinerator operation
procedures.

60.4910(c)(1)

Records of names of persons who have completed review of
the site-specific information and incinerator operating
procedures in 60.4910(c)(1).

60.4910(c)(1)

Records of names of persons who have completed the operator
training requirements. Includes documentation of the training
and the dates of the training.

60.4910(c)(2)

Records showing the periods when no qualified operators were
accessible for more than 8 hours, but less than two weeks.

60.4910(c)(3)

Records showing the periods when no qualified operators were
accessible for two weeks or more.

60.4910(c)(4)

Records of control device inspections.

60.4910(d)

Records of initial performance tests, annual performance tests,
and any subsequent performance tests.

60.4910(e)

Records of all continuous monitoring data; includes continuous
emissions monitors, continuous automated sampling systems,
and continuous parameter monitors.

60.4910(f)

Records of other info for continuous monitoring systems.

60.4910(g)

Records of days when a deviation from the operating or
emission limits have occurred. Includes a description of the
deviation and a description of the corrective actions taken.

60.4910(h)

ATTACHMENT 1
SOURCE DATA AND INFORMATION REQUIREMENTS
40 CFR
60 Subpart LLLL

Requirement
Equipment vendor specifications for the incinerator, emission
controls, and monitoring equipment.

60.4910(i)

Records of calibration of any monitoring devices.

60.4910(j)

Records of monitoring plan and performance evaluations.

60.4910(k)

Records of less frequent testing.

60.4910(l)

Records of use of bypass stack.

60.4910(m)

REPORTING
Submit notification of construction
•
•
•
•

60.4915(a)

statement of intent to construct
anticipated date of commencement of construction
documentation for siting requirements
anticipated date of initial startup

Submit startup notification
•
•
•
•
•

60.4915(b)

maximum design dry sewage sludge burning capacity
anticipated maximum feed rate
if applicable, the petition for site-specific operating
limits
anticipated date of initial startup
site-specific monitoring plan

Report the following information no later than 60 days after
the initial performance test:
•
•
•
•
•

Complete test report for the initial performance test
Results of CMS performance evaluation
The values for the site-specific operating limits
Documentation of installation of bag leak detection
system for fabric filter
Results of initial air pollution control device inspection

60.4915(c)

ATTACHMENT 1
SOURCE DATA AND INFORMATION REQUIREMENTS
40 CFR
60 Subpart LLLL

Requirement
Report the following information annually:
•
•

•
•
•

•
•

•
•
•

60.4915(d)

If a performance test was conducted during the
reporting period, the results of the test
Highest recorded 3-hour average and the lowest 3-hour
average, as applicable, for each pollutant and operating
parameter recorded using a CMS for the calendar year
being reported
If no deviation occurred, a statement of no deviation
If a fabric filter is used, the date, time, and duration of
alarms
If a performance test was not conducted during the
reporting period, a statement that the requirements of
§60.4885(a)(3) were met
If a performance evaluation of a CMS was conducted,
the results
Documentation of periods when all qualified SSI unit
operators were unavailable for more than 8 hours but
less than 2 weeks
Results of annual pollution control device inspection
Statements on if CMS malfunctioned or was out of
control.
If there were no operator training deviations, a
statement that there were no such deviations

If a deviation from operating limits or emission limits occurs,
submit a deviation report that includes the following
information:
•
•
•
•
•
•

Dates and times of deviation
Averaged and recorded data for those dates
Duration and causes of each deviation and the
corrective actions taken
Copy of operating parameter monitoring data and any
test reports
Dates, times, and causes for monitor downtime incidents
If CMS malfunctions or is out of control, include the
information specified in §60.4915(e)(3)(viii)

60.4915(e)

ATTACHMENT 1
SOURCE DATA AND INFORMATION REQUIREMENTS
40 CFR
60 Subpart LLLL

Requirement
If all qualified operators are unavailable for more than 2 weeks,
submit a notification of the deviation within 10 days and a
corrective action summary every 4 weeks

60.4915(f)

Report the following information if a force majeure occurs:

60.4915(g)

•
•
•
•

Description of the force majeure event
Rationale for attributing the delay to the force majeure
Description of measures taken to minimize the delay
Identification of date by which you propose to conduct
the performance test

Submit a notification 1 month prior if you intend to start or
stop use of a CMS

60.4915(h)

Submit a notification 30 days prior if you intend to conduct a
performance test

60.4915(h)

Submit a notification at least 7 days in advance if you intend to
reschedule a performance test

60.4915(h)

ATTACHMENT 2
TABLES 1, 2, 3, and 4

Table 1:

Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Standards of Performance for New Stationary Sources:
Sewage Sludge Incineration Units - Subpart LLLL - Year 1

Table 2:

Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Standards of Performance for New Stationary Sources:
Sewage Sludge Incineration Units - Subpart LLLL - Year 2

Table 3:

Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Standards of Performance for New Stationary Sources:
Sewage Sludge Incineration Units - Subpart LLLL - Year 3

Table 4:

Summary of Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Standards of Performance for New Stationary
Sources: Sewage Sludge Incineration Units - Subpart LLLL

ATTACHMENT 3
TABLES 5, 6, 7, and 8

Table 5:

Annual Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements of the Standards of Performance for New Stationary
Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 1

Table 6:

Table 7:

Table 8:

Summary of Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements of the Standards of Performance for New Stationary
Sources: Sewage Sludge Incineration Units - Subpart LLLL

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 1
Emission
Testing
Contractor
Hours
Per
Occurrence

Non-Labor
Costs
Per
Occurrence

$100

1) Initial stack test and report

Incl. in E.

varies

$71,000

2) Annual stack test and test report

Incl. in E.

766

$61,240

a) Establish and teach operator qualification course

128

b) Obtain operator qualification

144

c) Annual refresher course

Burden Item

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

1. Applications

N/A

2. Surveys and Studies

N/A

(B)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Number of
Respondents
Per Year

(E)
Technical
Hours
Per Year

(F)
Management
Hours
Per Year

(G)
Clerical
Hours
Per Year

(CXD)

(E x 0.05)

(E x 0.1)

(H)
Emission
Testing
Contractor
Hours Per
Year

6
7

Total
Labor Costs
Per Year

Total
Non-Labor
Costs
Per Year

Total
Responses
Per Year

Footnotes

$131

$200

a,b,i

1,775

$142,000

$8,368

a,b

$9,414

a,b

3. Reporting Requirements
A. Read and Understand Rule Requirements
B. Required Activities

Operator training and qualification

d) Initial review of site-specific information
e) Annual review of site-specific information

Incl. in a.
8

Incl. in B.1

$5,230

a) Initial capital costs

$226,946

$453,892

a,d

b) Annualized capital and O&M costs

$81,160

$1,438

$162,320

c,e

4) Establish operating parameters (maximum and minimum)
5) Continuous parameter monitoring (including CEMS)

C. Create Information

Incl. in 3.B

D. Gather Information

Incl. in 3.E

E. Report Preparation
1) Notification of initial performance test
a) Pollutants, opacity

$262

b) Fugitive Ash Emissions

$131

$262

a) Pollutants, opacity

$7.50

$1,046

$15

b) Fugitive Ash Emissions

$262

160

320

$20,921

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report prior to construction (includes siting analysis)

Incl. in 3.B.5
160

6) Report prior to initial start-up

a
a

a) Without site specific parameter petition

$785

b) With site specific parameter petition

$7.50

$523

$1,046

$7.50

$3,138

$15

810

1,775

$52,956

$304,550

7) Report of initial stack test

Incl. in 3.B.1

8) Annual Report:
a) Results of performance tests conducted during the year
9) Status report for operators that are off-site for more
than 2 weeks
10) Corrective action summary for operators that are off-site
for more than 2 weeks
11) Semiannual report of emissions/parameter exceedances
ReportingSubtotal

Burden Item

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

Emission
Testing
Contractor
Hours
Per
Occurrence

Non-Labor
Costs
Per
Occurrence

(B)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Number of
Respondents
Per Year

Incl. in 3.B.5

1.5

(E)
Technical
Hours
Per Year

(F)
Management
Hours
Per Year

(G)
Clerical
Hours
Per Year

(CXD)

(E x 0.05)

(E x 0.1)

(H)
Emission
Testing
Contractor
Hours Per
Year

1.5

Total
Labor Costs
Per Year

Total
Non-Labor
Costs
Per Year

Total
Responses
Per Year

$98

Footnotes

4. Recordkeeping Requirements
A. Read Instructions

Incl. in 3.A

B. Plan Activities

N/A

C. Implement Activities

N/A

D. Develop Record System

N/A

E. Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters

3) Records of stack tests

Incl. in 3.E

4) Records of siting analysis

Incl. in 3.E

5) Records of persons who have reviewed operating procedures

6) Records of persons who have completed operator training

7) Records of persons who meet operator qualification criteria

Recordkeeping Subtotal

1.5

0.075

0.15

$98

TOTAL:

812

1,775

$53,054

$304,550

Total Hours

Labor

Non-Labor

Total

933

$53,054

$304,550

$357,604

8) Records of monitoring device calibration
9) Records of site-specific documentation
F. Personnel Training
G. Time for Audits

Incl. in 3.B
24
Incl. in 3.B
N/A

Summary of Respondent Burden
Initial Capital and Startup

$454,092

Annualized Capital/Start-up and O & M

$304,550

FOOTNOTES
a One-time only costs.
b Cost incurred by a facility regardless of the number of affected units at the plant.
c Annual cost. Annual costs are not incurred until the second year of operation.
d Based on the sum of the total capital costs for each monitoring system required for incinerators.
e Based on the sum of the annualized capital costs for each monitoring system required for incinerators.
f Assumed that none of the facilities will petition for site-specific parameters.
g Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. Assumed that this required only two corrective action summaries.
h Assumed that 10 percent of the facilities would have an exceedance during the year.
i Assumed $100 for puchase of filing cabinet to house copy of rule, records and report copies.

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 2
Emission
Testing
Contractor
Hours
Per
Occurrence

Non-Labor
Costs
Per
Occurrence

1) Initial stack test and report

Incl. in E.

varies

2) Annual stack test and test report

Incl. in E.

766

$61,240

1,531

$122,480

a) Establish and teach operator qualification course

a,b

b) Obtain operator qualification

a,b

c) Annual refresher course

$1,569

Burden Item

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

1. Applications

N/A

2. Surveys and Studies

N/A

(B)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Number of
Respondents
Per Year

(E)
Technical
Hours
Per Year

(F)
Management
Hours
Per Year

(G)
Clerical
Hours
Per Year

(CXD)

(E x 0.05)

(E x 0.1)

(H)
Emission
Testing
Contractor
Hours Per
Year

Total
Labor Costs
Per Year

Total
Non-Labor
Costs
Per Year

Total
Responses
Per Year

Footnotes

a,b,i

3. Reporting Requirements
A. Read and Understand Rule Requirements
B. Required Activities

Operator training and qualification

d) Initial review of site-specific information
e) Annual review of site-specific information
4) Establish operating parameters (maximum and minimum)

Incl. in a.
8

$1,046

Incl. in B.1

5) Continuous parameter monitoring (including CEMS)
a) Initial capital costs

a,d

b) Annualized capital and O&M costs

$81,160

$1,438

$162,320

c,e

C. Create Information

Incl. in 3.B

D. Gather Information

Incl. in 3.E

E. Report Preparation
1) Notification of initial performance test
a) Pollutants, opacity

b) Fugitive Ash Emissions

a) Pollutants, opacity

$7.50

b) Fugitive Ash Emissions

160

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report prior to construction (includes siting analysis)

Incl. in 3.B.5
160

6) Report prior to initial start-up
a) Without site specific parameter petition

b) With site specific parameter petition

$7.50

$5,230

$15

$523

7) Report of initial stack test

a
a

Incl. in 3.B.1

8) Annual Report:
a) Results of performance tests conducted during the year
9) Status report for operators that are off-site for more
than 2 weeks

10) Corrective action summary for operators that are off-site
for more than 2 weeks
11) Semiannual report of emissions/parameter exceedances
ReportingSubtotal

$1,046

$7.50

$3,138

$15

214

1,531

$13,991

$284,830

Burden Item

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

Emission
Testing
Contractor
Hours
Per
Occurrence

Non-Labor
Costs
Per
Occurrence

(B)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Number of
Respondents
Per Year

Incl. in 3.B.5

1.5

(E)
Technical
Hours
Per Year

(F)
Management
Hours
Per Year

(G)
Clerical
Hours
Per Year

(CXD)

(E x 0.05)

(E x 0.1)

(H)
Emission
Testing
Contractor
Hours Per
Year

1.5

Total
Labor Costs
Per Year

Total
Non-Labor
Costs
Per Year

Total
Responses
Per Year

$98

Footnotes

4. Recordkeeping Requirements
A. Read Instructions

Incl. in 3.A

B. Plan Activities

N/A

C. Implement Activities

N/A

D. Develop Record System

N/A

E. Record Information
1) Records of operating parameters

2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.E

4) Records of siting analysis

Incl. in 3.E

5) Records of persons who have reviewed operating procedures

$131

6) Records of persons who have completed operator training

$131

7) Records of persons who meet operator qualification criteria

$131

$3,138

Recordkeeping Subtotal

55.5

2.775

5.55

$3,628

TOTAL:

270

1,531

$17,619

$284,830

Total Hours

Labor

Non-Labor

Total

310

$17,619

$284,830

$302,449

8) Records of monitoring device calibration

Incl. in 3.B

9) Records of site-specific documentation
F. Personnel Training

24
Incl. in 3.B

G. Time for Audits

N/A

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

$0
$284,830

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL - Year 3
Emission
Testing
Contractor
Hours
Per
Occurrence

Non-Labor
Costs
Per
Occurrence

1) Initial stack test and report

Incl. in E.

varies

2) Annual stack test and test report

Incl. in E.

766

$61,240

1,531

$122,480

Burden Item

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

1. Applications

N/A

2. Surveys and Studies

N/A

(B)
Number of
Occurrences
Per
Respondent
Per Year

(D)
Number of
Respondents
Per Year

(E)
Technical
Hours
Per Year

(F)
Management
Hours
Per Year

(G)
Clerical
Hours
Per Year

(CXD)

(E x 0.05)

(E x 0.1)

(H)
Emission
Testing
Contractor
Hours Per
Year

Total
Labor Costs
Per Year

Total
Non-Labor
Costs
Per Year

Total
Responses
Per Year

Footnotes

a,b,i

3. Reporting Requirements
A. Read and Understand Rule Requirements
B. Required Activities

Operator training and qualification
a) Establish and teach operator qualification course

a,b

b) Obtain operator qualification

a,b

c) Annual refresher course

$1,569

d) Initial review of site-specific information
e) Annual review of site-specific information

Incl. in a.
8

$1,046

Incl. in B.1

a) Initial capital costs

a,d

b) Annualized capital and O&M costs

$81,160

$1,438

$162,320

c,e

4) Establish operating parameters (maximum and minimum)
5) Continuous parameter monitoring (including CEMS)

C. Create Information

Incl. in 3.B

D. Gather Information

Incl. in 3.E

E. Report Preparation
1) Notification of initial performance test
a) Pollutants, opacity

b) Fugitive Ash Emissions

a) Pollutants, opacity

$7.50

b) Fugitive Ash Emissions

160

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report prior to construction (includes siting analysis)

Incl. in 3.B.5
160

6) Report prior to initial start-up
a) Without site specific parameter petition

b) With site specific parameter petition

$7.50

$5,230

$15

$523

7) Report of initial stack test

a
a

Incl. in 3.B.1

8) Annual Report:
a) Results of performance tests conducted during the year
9) Status report for operators that are off-site for more
than 2 weeks

10) Corrective action summary for operators that are off-site
for more than 2 weeks
11) Semiannual report of emissions/parameter exceedances
ReportingSubtotal

$1,046

$7.50

$3,138

$15

214

1,531

$13,991

$284,830

Emission
Testing
Contractor
Hours
Per

Non-Labor
Costs
Per
Occurrence

(B)
Number of
Occurrences
Per
Respondent

(D)
Number of
Respondents
Per Year

(E)
Technical
Hours
Per Year

(F)
Management
Hours
Per Year

(G)
Clerical
Hours
Per Year

(H)
Emission
Testing
Contractor
Hours Per

Total
Labor Costs
Per Year

Total
Non-Labor
Costs
Per Year

Total
Responses
Per Year

Incl. in 3.B.5

1.5

$98

Footnotes

4. Recordkeeping Requirements
A. Read Instructions

Incl. in 3.A

B. Plan Activities

N/A

C. Implement Activities

N/A

D. Develop Record System

N/A

E. Record Information
1) Records of operating parameters

2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.E

4) Records of siting analysis

Incl. in 3.E

5) Records of persons who have reviewed operating procedures

$131

6) Records of persons who have completed operator training

$131

7) Records of persons who meet operator qualification criteria

$131

$3,138

Recordkeeping Subtotal

55.5

2.775

5.55

$3,628

TOTAL:

270

1,531

$17,619

$284,830

Total Hours

Labor

Non-Labor

Total

310

$17,619

$284,830

$302,449

8) Records of monitoring device calibration
9) Records of site-specific documentation
F. Personnel Training
G. Time for Audits

Incl. in 3.B
24
Incl. in 3.B
N/A

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

$0
$284,830

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of
Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL

Year
1
2
3
Total
Average

Technical Hours

Management Hours

Clerical Hours

Total Hours

Testing
Contractor
Hoursa

812
270
270
1,351
450

41
13
13
68
23

81
27
27
135
45

933
310
310
1,553
518

1,775
1,531
1,531
4,837
1,612

a. Test contractor costs are accounted for in the non-labor category

Labor Costs

Non-Labor
(Annualized
Capital/Startup and
O&M) Costs

$53,054
$17,619
$17,619
$88,293
$29,431

$304,550
$284,830
$284,830
$874,210
$291,403

Total Costs
$357,604
$302,449
$302,449
$962,503
$320,834

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units Subpart LLLL - Year 1

Burden Item

(A)

(B)

Number of Occurrences
Per Year

EPA Hours Per
Occurrence

(C)

(E)

Tech Hours Per Management Hours Per Clerical Hours Per
Year (C=AxB)
Year (D=Cx0.05)
Year (E=Cx0.1)

1. Applications
2. Read and Understand Rule Requirements

(D)

(F)

EPA Cost Per
Year (a,b)

not applicable
1

$829

$2,487

$1,244

3. Required Activities
A. Observe initial stack tests
B.

Excess emissions -- Enforcement Activities

Create Information

not applicable

Gather Information

not applicable

Report Reviews

Review report submitted prior to initial startup

$207

Review initial stack test report

$4,146

Review annual compliance report

Review semi-annual excess emission and parameter exceedance report

$1,658

Review status reports and corrective action summary for operators off-site

$622

Prepare annual summary report

5. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL

FOOTNOTES
a Figures may not add exactly due to rounding.
b Assumes EPA personnel attend 20 percent of the initial stack tests.
c Using four hours per state to write annual summary report.

0
$881

224

1
per trip

$415
$881

$12,489

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units Subpart LLLL - Year 2

Burden Item

(A)

(B)

Number of Occurrences
Per Year

EPA Hours Per
Occurrence

(C)

(E)

Tech Hours Per Management Hours Per Clerical Hours Per
Year (C=AxB)
Year (D=Cx0.05)
Year (E=Cx0.1)

(F)

EPA Cost Per
Year (a,b)

not applicable

1. Applications
2. Read and Understand Rule Requirements

(D)

3. Required Activities
A. Observe initial stack tests

$1,244

Excess emissions -- Enforcement Activities

Create Information

not applicable

Gather Information

not applicable

Report Reviews

Review report submitted prior to initial startup

Review initial stack test report

Review annual compliance report

$829

Review semi-annual excess emission and parameter exceedance report

$1,658

Review status reports and corrective action summary for operators off-site

$622

$415

$4,768

Prepare annual summary report

5. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL

FOOTNOTES
a Figures may not add exactly due to rounding.
b Assumes EPA personnel attend 20 percent of the initial stack tests.
c Using four hours per state to write annual summary report.

0
$0

per trip

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the Standards of Performance for New
Stationary Sources: Sewage Sludge Incineration Units Subpart LLLL - Year 3

Burden Item

(A)

(B)

Number of Occurrences
Per Year

EPA Hours Per
Occurrence

(C)

(E)

Tech Hours Per Management Hours Per Clerical Hours Per
Year (C=AxB)
Year (D=Cx0.05)
Year (E=Cx0.1)

(F)

EPA Cost Per
Year (a,b)

not applicable

1. Applications
2. Read and Understand Rule Requirements

(D)

3. Required Activities
A. Observe initial stack tests

$1,244

Excess emissions -- Enforcement Activities

Create Information

not applicable

Gather Information

not applicable

Report Reviews

Review report submitted prior to initial startup

Review initial stack test report

Review annual compliance report

$829

Review semi-annual excess emission and parameter exceedance report

$1,658

Review status reports and corrective action summary for operators off-site

$622

$415

Prepare annual summary report

5. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL

FOOTNOTES
a Figures may not add exactly due to rounding.
b Assumes EPA personnel attend 20 percent of the initial stack tests.
c Using four hours per state to write annual summary report.

0
$0

per trip

$0
9

$4,768

Table 8 - Summary of Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of the Standards of Performance for New Stationary Sources: Sewage Sludge Incineration Units - Subpart LLLL
Year
1
2
3
Total
Average

Technical Hours Management Hours
224
92
92
408
136

11
5
5
20
7

Clerical Hours

Total Hours

Labor Costs

Non-Labor
Costs

Total Costs

22
9
9
41
14

258
106
106
469
156

$12,489
$4,768
$4,768
$22,025
$7,342

$0
$0
$0
$0
$0

$12,489
$4,768
$4,768
$22,025
$7,342

File Type	application/pdf
File Modified	2010-08-18
File Created	2010-08-18