Burden Tables

---

Overview

Table 1A
Table 1B
Table 2
Capital and O&M

---

Sheet 1: Table 1A

Table 1A: Annual Respondent Burden and Cost – Emission Guidelines for Sewage Sludge Incinerators (40 CFR Part 60, Subpart MMMM) (Renewal)
					122.66	149.84	60.88
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent Hours per Occurrence	Number of Occurrences Per Respondent Per Year	Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CxD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarize with the regulatory requirements c, d	40	1	40	86	3,440	172	344	$468,666
B. Required Activities
1) Initial stack test and report e	40	1	40	0	0	0	0	$0
2) Annual stack test and test report f, g	40	0.33	13.2	170	2,244	112.2	224	$305,722.56
3) Operator training and qualification
a) Establish and teach operator qualification course d, e	64	1	64	0	0	0	0	$0
b) Obtain operator qualification d, e	72	1	72	0	0	0	0	$0
c) Annual refresher course d, f	12	1	12	86	1,032	51.6	103	$140,599.68
d) Initial review of site-specific information	See 3B
e) Annual review of site-specific information d, f	8	1	8	86	688	34.4	68.8	$93,733.12
4) Establish operating parameters (maximum and minimum) e	40	1	40	0	0	0	0	$0
5) Continuous parameter monitoring (including CEMS)
a) Initial monitoring e	11	1	11	0	0	0	0	$0
b) Annual monitoring f	11	1	11	170	1,870	93.5	187	$254,768.80
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
1) Notification of initial performance test e	2	1	2	0	0	0	0	$0
2) Notification of initial CMS Demonstration d, e	2	1	2	0	0	0	0	$0
3) Final Control Plan e	20	1	20	0	0	0	0	$0
4) Initial Compliance Report e	40	1	40	0	0	0	0	$0
5) Report for site-specific parameter petition e, h	14	1	14	0	0	0	0	$0
6) Annual Compliance Report	40	1	40	170	6,800	340	680	$926,432.00
7) Notification for operators that are off-site for more than 2 weeks i	8	1	8	9	72	3.6	7.2	$9,809.28
8) Status report for operators that are off-site for more than 2 weeks i	8	2	16	9	144	7.2	14.4	$19,618.56
9) Semiannual Deviation Report j	24	2	48	9	432	21.6	43.2	$58,855.68
Subtotal for Reporting Requirements					19,230			$2,278,205
4. Recordkeeping Requirements
A. Familiarize with the regulatory requirements	See 3A
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	52	104	86	8,944	447	894	$1,218,531
2) Records of exceedances of the operating parameters j	2	1	2	9	18	0.9	1.8	$2,452.32
3) Records of stack tests g	2	0.33	0.66	86	56.76	2.84	5.68	$7,732.98
4) Records of persons who have reviewed operating procedures	2	1	2	86	172	8.6	17.2	$23,433.28
5) Records of persons who have completed operator training	2	1	2	86	172	8.6	17.2	$23,433.28
6) Records of persons who meet operator qualification criteria	2	1	2	86	172	8.6	17.2	$23,433.28
7) Records of monitoring device calibration	2	1	2	86	172	8.6	17.2	$23,433.28
8) Records of site-specific documentation	24	1	24	86	2,064	103	206	$281,199.36
F. Personnel Training	See 3B
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					13,536			$1,603,648		responses	hr/response
Total Labor Burden and Costs (rounded) k					32,800			$3,880,000		271	121
Total Capital and O&M Cost (rounded) k								$1,350,000
GRAND TOTAL (rounded) k								$5,230,000
Assumptions:
a We have assumed that there will be an average of 170 units at 86 facilities that will be subject to the rule. Because the standard only affects existing units constructed on or before October 14, 2010; there will be no new units subject to the rule.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that all existing respondents will have to familiarize with the regulatory requirements each year.
d Cost incurred by a facility regardless of the number of affected units at the plant.
e This is a one-time only cost.
f Annual costs are not incurred until the second year of operation.
g Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements.
h We have assumed that none of the facilities will petition for site-specific parameters.
i We have assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year (86 x 10% = 8.6, rounded to 9 facilities). We have also assumed that this required only two status reports.
j We have assumed that 10 percent of the facilities would have an exceedance during the year (86 x 10% = 8.6, rounded to 9 facilities).
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Table 1B

Table 1B: Average Annual State/Local Agency Burden and Cost – Emission Guidelines for Sewage Sludge Incinerators (40 CFR Part 60, Subpart MMMM) (Renewal)
					51.23	69.04	27.73
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	State/Local Agency Hours per Occurrence	Number of Occurrences Per Respondent Per Year	State/Local Agency Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CxD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Annual Costs ($/year) b
1. Applications	N/A
2. Read and Understand Rule Requirements	40	1	40	0	0	0	0	$0
3. Required Activities
A. Observe stack tests c	48	1	48	7	336	16.8	33.6	$19,304.88
B. Excess emissions -- Enforcement Activities d	24	1	24	5	120	6	12	$6,894.60
C. Create Information	N/A
D. Gather Information	N/A
E. Report Reviews
1) Review initial notifications	20	1	20	0	0	0	0	$0
2) Review initial compliance report	40	1	40	0	0	0	0	$0
3) Review annual compliance report	8	1	8	102	816	40.8	81.6	$46,883.28
4) Review semiannual excess emission and parameter exceedance report d	16	2	32	5	160	8	16	$9,192.80
5) Review notification and status reports for operators off-site e	4	3	12	5	60	3	6	$3,447.30
F. Prepare annual summary report f	3	1	3	48	144	7.2	14.4	$8,273.52
5. Travel expenses: (1 person * 48 hours per trip / 8 hours per day * $75 per diem) + ($600 per round trip) = $1,050 per trip ($1,050 per trip x 11 trips) = $11,550								$11,550
TOTAL (rounded) g					1,880			$106,000
Assumptions
a We have assumed that there will be an average of 170 units at 86 facilities that will be subject to the rule. We assume that 9 states/local jurisdictions (consisting of 48 facilities and 102 incinerator units) have been delegated authority by EPA and that 15 states/local jurisdictions (consisting of 38 facilities and 68 incinerator units) will operate under the Federal Plan.
b This cost is based on the following labor rates: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). The rates have been increased by 60 percent to account for the benefit packages available to government employees. These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay.
c We assume that State/local agency personnel attends 20 percent of the stack tests. Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements. (102 units per year x 0.333 stack test/unit x 20%) = 6.79, rounded to 7 stack tests per year)
d We assume that 10 percent of the 48 facilities would have an exceedance during the year (48 x 10% = 4.8, rounded to 5 facilities).
e We assume that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. We assume that this will require only two status reports, resulting in a total of 3 reports (1 notification and 2 status reports).
f We assume that the 9 states/local agencies that have been delegated authority will take 3 hours per SSI facility to prepare the annual summary report for the 48 sewage sludge incinerator facilities in state/local jurisdictions.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – Emission Guidelines for Sewage Sludge Incinerators (40 CFR Part 60, Subpart MMMM and Federal Plan) (Renewal)
					51.23	69.04	27.73
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CxD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Annual Costs ($/year) b
1. Applications	N/A
2. Read and Understand Rule Requirements	40	1	40	0	0	0	0	$0
3. Required Activities
A. Observe stack tests c	48	1	48	5	240	12	24	$13,789.20
B. Excess emissions -- Enforcement Activities d	24	1	24	4	96	4.8	9.6	$5,515.68
C. Create Information	N/A
D. Gather Information	N/A
E. Report Reviews
1) Review initial notifications	20	1	20	0	0	0	0	$0
2) Review initial compliance report	40	1	40	0	0	0	0	$0
3) Review annual compliance report	8	1	8	68	544	27.2	54.4	$31,255.52
4) Review semiannual excess emission and parameter exceedance report d	16	2	32	4	128	6.4	12.8	$7,354.24
5) Review notification and status reports for operators off-site e	4	3	12	4	48	2.4	4.8	$2,757.84
F. Prepare annual summary report f	3	1	3	38	114	5.7	11.4	$6,549.87
5. Travel expenses: (1 person * 48 hours per trip / 8 hours per day * $75 per diem) + ($600 per round trip) = $1,050 per trip ($1,050 per trip x 11 trips) = $11,550								$11,550
TOTAL (rounded) g					1,350			$78,800
Assumptions
a We have assumed that there will be an average of 170 units at 86 facilities that will be subject to the rule. We assume that 9 states/local jurisdictions (consisting of 48 facilities and 102 incinerator units) have been delegated authority by EPA and that 15 states/local jurisdictions (consisting of 38 facilities and 68 incinerator units) will operate under the Federal Plan.
b This cost is based on the following labor rates: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). The rates have been increased by 60 percent to account for the benefit packages available to government employees. These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay.
c We assume that EPA personnel attends 20 percent of the stack tests. Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements. (68 units per year x 0.333 stack test/unit x 20%) = 4.53, rounded to 5 stack tests per year)
d We assume that 10 percent of the 38 facilities would have an exceedance during the year (38 x 10% = 3.8, rounded to 4 facilities).
e We assume that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. We assume that this will require only two status reports, resulting in a total of 3 reports (1 notification and 2 status reports).
f We assume that EPA will take 3 hours per SSI facility to prepare the annual summary report for the 38 sewage sludge incinerator facilities operating under the Federal Plan.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 4: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Fluidized Bed
PBS parameter monitors	$24,300	0	$0	$5,600	6	$33,600
SNCR monitors	$10,300	0	$0	$3,200	2	$6,400
Initial and annual stack test	$61,740	0	$0	$21,348	18	$384,264
Multiple Hearth
PBS parameter monitors	$24,300	0	$0	$5,600	8	$44,800
Initial and annual stack test	$61,740	0	$0	$23,302	38	$885,476
Total			$0			$1,350,000
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	86	0	0	86
2	0	86	0	0	86
3	0	86	0	0	86
Average	0	86	0	0	86
1 New respondents include sources with constructed, reconstructed and modified
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of performance test	0	1	0	0
Notification of CMS demonstration	0	1	0	0
Final control plan	0	1	0	0
Initial compliance report	0	1	0	0
Annual stack test a	56	1	0	56
Annual compliance report b	170	1	0	170
Qualified operator notification c	9	1	0	9
Qualified operator status report c	9	2	0	18
Semiannual Deviation Report d	9	2	0	18
			Total	271	hours/response	121
a Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements. Number of tests per year = 170 / 3 = 56.1, rounded to 56 tests per year.
b Based on the number of SSI units.
c Assumed that 10 percent of the facilities would not have a qualified operator available for more than two weeks at least once a year. We assumed that this required only two status reports. 86 facilities x 10% = 8.6, rounded to 9 facilities.
d Assumed that 10 percent of the facilities would have an exceedance during the year. 86 facilities x 10% = 8.6, rounded to 9 facilities.