SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Sewage Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Sewage Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal), EPA 

ICR Number 2369.03, OMB Control Number 2060-0658

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Sewage Sludge Incineration Units 

(40 CFR part 60, subpart LLLL) were proposed on October 14, 2010 (75 FR 63260) and 

promulgated on March 21, 2011 (76 FR 15372). These regulations apply to new facilities, which 

include those with a sewage sludge incineration (SSI) unit constructed after the date of proposal

or commenced modification later than six months after the promulgation of the final standards. 

This information is being collected to assure compliance with 40 CFR part 60, subpart LLLL.

In general, all NSPS standards require initial notification reports, performance tests, 

and periodic reports by the owners/operators of the affected facilities. They are also required 

to maintain records of the occurrence and duration of any startup, shutdown, or malfunction 

in the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. 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 U. S.

Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of one 

affected facility at each plant site, and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

According to the National Association of Clean Water Agencies (NACWA), most 

facilities with operating units will comply with the existing source emission limits, rather than 

the NSPS limits, because they were constructed or modified before the applicable NSPS dates. 

However, one existing source intends to comply with the NSPS due to modification after the 

applicable date, and there are two utilities that have already initiated, or plan to initiate,

construction of new SSI units. Therefore, although currently there are no respondents subject to 

the standards, we anticipate that three facilities will become subject over the next three years. 

For the purposes of calculating the “burden”, we assume an average of one respondent per year 

will become subject to the standards.
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 Based on the assumed distribution of new or modified facilities with affected sewage 

sludge incinerators, there are three facilities which will be affected: two newly constructed SSI units 

and one modified unit are expected to be subject to the standards. These facilities are assumed to be 

located in the public sector. The “burden” to the “Affected Public” may be found below in Table 

1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge Incineration Units (40 CFR 

Part 60, Subpart LLLL) (Renewal). The “burden” to the Federal Government is attributed 

entirely to work performed by either Federal employees or government contractors and is 

presented in below Table 2: Average Annual EPA Burden and Cost – NSPS for Sewage Sludge 

Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal).

The Office of Management and Budget (OMB) approved the currently active 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 addition, section 114(a) states that the Administrator may require any owner/operator 

subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 
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and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, particulate matter (PM), hydrogen chloride (HCl), 

carbon monoxide (CO), dioxin/furan, mercury (Hg), oxides of nitrogen (NOx), sulfur dioxide 

(SO2), cadmium, lead, and fugitive emissions from sewage sludge incineration either cause or 

contribute to air pollution that may reasonably be anticipated to endanger public health and/or 

welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60,

subpart LLLL.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors or continuous 

parametric monitors are used to ensure compliance with the standard at all times. During the 

performance test, a record of the operating parameters under which compliance was achieved 

may be recorded and used to determine compliance in place of a continuous emission monitor. 

The notifications required in the standard 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/or) leaks are being detected and repaired and the standard is being 

met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

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

LLLL.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency 

can be sent to the Administrator in lieu of the report required by the Federal standards. 

Therefore, duplication does not exist.
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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 (FR citation, e.g., 78 FR 35023) on June 11, 2013. No comments were 

received on the burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s 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 three respondents 

will be subject to the standard over the three year period covered by this ICR.

Industry trade associations 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. In developing this ICR, we contacted: 1) the National Association of Clean Water 

Agencies, at (202)833-9106; and 2) the Water Environment Federation, at (703)684-2437.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five-years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance, and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 
5

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standards do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of new or modified SSI units. The United States Standard Industrial Classification (SIC) code 

for the respondents affected by the standards is SIC 49539907, which corresponds to the North 

American Industry Classification System (NAICS) code 221320 for Sewage Treatment 

Facilities. 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Sewage 

Sludge Incineration Units (40 CFR Part 60, Subpart LLLL). 

A source must make the following reports:

Notifications

Notification of intent to construct, including anticipated date of 

commencement of construction, documentation for siting 

requirements, and anticipated date of initial startup.

60.4915(a)

Notification of actual startup, including maximum design dry sewage 

sludge burning capacity, anticipated maximum feed rate, petition for 

site-specific operating limits if applicable, and site-specific 

monitoring plan.

60.4915(b)
6

Notifications

Notification of intent to start or stop use of a CMS. 60.4915(h)

Notification of performance test. 60.4915(h)

Notification to reschedule performance test. 60.4915(h)

Reports

Initial compliance report, no later than 60 days after initial 

performance test.

60.4915(c)

Annual compliance report. 60.4915(d)

Deviation report if operating limits or emission limits are exceeded. 60.4915(e)

Report of force majeure event occurrences. 60.4915(g)

A source must keep the following records:

Recordkeeping

Maintain all records for five years. 60.4910

Record calendar date of each record. 60.4910(a)

Maintain records of documentation of siting requirements. 60.4910(b)

Maintain records of site-specific information and incinerator operation 

procedures and the names of persons who have completed review of 

this information.

60.4910(c)(1)

Maintain records of names of persons who have completed the 

operator training requirements, including documentation of the training 

and the dates of the training.

60.4910(c)(2)

Maintain records showing the periods when no qualified operators 

were accessible for more than 8 hours, but less than two weeks. 60.4910(c)(3)

Maintain records showing the periods when no qualified operators 

were accessible for two weeks or more. 60.4910(c)(4)

Maintain records of control device inspections. 60.4910(d)

Maintain records of initial performance tests, annual performance tests, 

and any subsequent performance tests.

60.4910(e)
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Recordkeeping

Maintain records of all continuous monitoring data; includes 

continuous emissions monitors, continuous automated sampling 

systems, and continuous parameter monitors.

60.4910(f)

Maintain records of other information for continuous monitoring 

systems.

60.4910(g)

Maintain records of days when a deviation from the operating or 

emission limits have occurred, including a description of the deviation 

and a description of the corrective actions taken. 

60.4910(h)

Maintain equipment vendor specifications for the incinerator, emission 

controls, and monitoring equipment.

60.4910(i)

Maintain records of calibration of any monitoring devices. 60.4910(j)

Maintain records of monitoring plan and performance evaluations. 60.4910(k)

Maintain records of less frequent testing. 60.4910(l)

Maintain records of use of bypass stack. 60.4910(m)

Electronic Reporting

Some of the respondents may use monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting. 

(ii) Respondent Activities

Respondent Activities

Read and understand rule requirements.

Prepare siting analysis.

Establish and teach operator qualification course and obtain operator qualification.
8

Respondent Activities

Install, calibrate, maintain, and operate continuous parameter monitoring systems, including 

CEMS.

Perform initial performance test and establish operating limits for each operating parameter.

Continuously monitor operating parameters.

Conduct annual performance tests.

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.

Transmit, or otherwise disclose the information.

Sources will us monitoring and reporting equipment that provide parameter data in an 

automated way (e.g., continuous parameter monitoring system). 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.
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Agency Activities

Prepare an annual summary report.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard and note the operating conditions under which compliance was achieved.

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS 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/operator for five 

years.

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 conduct 

performance tests once every three years to show compliance if certain criteria are met. 

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) for all pollutants except for CO.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 
10

shown below in Table 1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge 

Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with 

the concept of burden under the Paperwork Reduction Act. Wherever 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 798 hours (Total Labor Hours from Table 1

below). 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 $123.04 ($58.59 + 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March

2013, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standards are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring and performance tests. The capital/startup costs are onetime costs when a facility becomes subject to the regulations. The annual operation and 

maintenance costs are the ongoing costs to maintain the monitors and other costs such as 
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photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

per Year

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

per Year 

with O&M

(G)

Total Annual 

O&M,

(E X F)

CPMS a $226,946 1 $226,946 $81,160 1 $81,160

Stack 

testing b

$61.350 1 $61.350 $0

Filing 

cabinet c

$100 1 $100 $0

Total $288,396 $81,160

a. Based on estimated monitoring costs provided in regulatory support documentation.

b. Total estimated cost for initial stack test, including Method 5 (PM), Method 9 (opacity), Method 10 (CO), Method 

26 (HCl), Method 29 (metals), Method 23 (CDD/CDF), Method 7E (NOx), and Method 6C (SO2). Facilities may 

test every three years if certain requirements are met, and it is assumed most facilities would meet the requirements. 

Thus, annual testing following the initial performance test is not considered over the 3-year period of this ICR.

c. Assumed $100 for purchase of filing cabinet to house copy of rule, records and report copies.

The total annual capital/startup costs for this ICR are $288,396. This is the total of 

column D in the above table. 

The total operation and maintenance (O&M) costs for this ICR are $81,160. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $369,556. These are 

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 

$14,510. 
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This cost is based on the average hourly labor rate as follows:

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

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

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

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Sewage 

Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

one existing respondents will be subject to the standards. It is estimated that one additional 

respondent per year will become subject to the standards. The overall average number of 

respondents, as shown in the table below, is two per year. 

This is based on industry data indicating no respondents are currently subject to the 

standards; however, two new units and one modified unit are expected to become subject to the 

standards within the next three years. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

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 0 0 0 1

2 1 1 0 0 2

3 1 2 0 0 3

Average 1 1 0 0 2

1

New respondent include sources with constructed, reconstructed and modified affected facilities. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 2. 
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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 1 1 0 1

Notification of start-up 1 1 0 1

Notification of initial 

performance test

1 1 0 1

Notification of initial CMS 

Demonstration

1 1 0 1

Initial Compliance Report 1 1 0 1

Annual Compliance Report a2 0 0 0

Status report for operators that are 

off-site for more than 2 week b

1 1 0 1

Corrective action summary for 

operators that are off-site for 

more than 2 weeks b

2 1 0 2

Semiannual Deviation Report 2 1 0 2

Total 10

a Facilities may test every three years if certain requirements are met, and it is assumed most facilities would meet the 

requirements.

b Assumed that 10 percent of the facilities (conservatively rounded to one) would not have a qualified operator available for 

more than two weeks at least once a year. Assumed this would require only two corrective action summaries. 

The total number of Annual Responses is 10.

The total annual labor costs are $78,068. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge Incineration 

Units (40 CFR Part 60, Subpart LLLL) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown below in Tables 1 and 2, respectively, and summarized below. 
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(i) Respondent Tally

The total annual labor hours are 798 hours at a cost of 78,068. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for 

Sewage Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection 

of information is estimated to average 80 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $369,556. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 322

labor hours at a cost of $14,510. See Table 2 below: Average Annual EPA Burden and Cost –

NSPS for Sewage Sludge Incineration Units (40 CFR Part 60, Subpart LLLL) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in respondent and Agency burden in this ICR compared to the 

previous ICR. The increase is due to an adjustment in the estimated number of sources. The 

previous ICR estimated two new units subject to the standard during the initial three-year 

compliance period. However, recent research indicates there are still no units subject to the 

standard at this time. Those same two new units are expected to become subject during threeyear period of this ICR, and another unit is expected to be modified and therefore, will also be 

subject to the NSPS. This change in estimate also results in an increase in the annual combined 

sums of the total capital/startup and O&M costs. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 80 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 
15

Numbers for EPA 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-2013-0321. 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), WJC 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 docket 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 Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2013-0321 and OMB Control Number 2060-0658 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge Incineration Units (40 CFR part 60, subpart LLLL)

(Renewal)

Burden item

(A)

Person hours 

per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours 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 b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d, h40 1 40 1 40 2 4 $4,499.59

 B. Required activities

i. Initial stack test and report c40 1 40 1 40 2 4 $4,499.59

ii. Annual stack test and report e, h40 1 40 0 0 0 0 $0

iii. Operator training and qualification 

a. Establish and teach operator qualification 

course c, d 64 1 64 1 64 3.2 6.4 $7,199.34

b. Obtain operator qualification c, d 72 1 72 1 72 3.6 7.2 $8,099.25

c. Annual refresher course 12 1 12 1 12 0.6 1.2 $1,349.88

d. Initial review of site-specific information See 3B (iii.a.)

e. Annual review of site-specific information e8 1 8 2 16 0.8 1.6 $1,799.83

iv. Establish operating parameters c40 1 40 1 40 2 4 $4,499.59

v. Continuous parameter monitoring (including 

CEMS) 11 1 11 2 22 1.1 2.2 $2,474.77

 C. Create information See 3B

 D. Gather existing information See 3E

 E. Write report 

i. Notification of construction/reconstruction and 

siting analysis c160 1 160 1 160 8 16 $17,998.34

ii. Notification of actual startup and monitoring 

plan 40 1 40 1 40 2 4 $4,499.59

iii. Notification of initial performance test c2 1 2 1 2 0.1 0.2 $224.98

iv. Notification of demonstration of CMS b2 1 2 1 2 0.1 0.2 $224.98

v. Initial compliance report 40 1 40 1 40 2 4 $4,499.59

vi. Annual compliance report 40 1 40 0 0 0 0 $0
17

Burden item

(A)

Person hours 

per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours 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 b

vii. Status report for operators that are off-site for 

more than 2 weeks f8 1 8 1 8 0.4 0.8 $899.92

viii. Corrective action summary for operators that 

are off-site for more than 2 weeks f8 2 16 1 16 0.8 1.6 $1,799.83

ix. Semiannual Deviation Report g24 2 48 1 48 2.4 4.8 $5,399.50

Subtotal for Reporting Requirements 715.3 $69,968.56

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities N/A

 C. Implement activities N/A

 D. Develop record system N/A

E. Record Information

i. Records of operating parameters 2 52 104 0 0 0 0 $0

ii. Records of exceedances of the operating 

parameters 2 1 2 1 2 0.1 0.2 $224.98

iii. Records of stack tests 2 1 2 2 4 0.2 0.4 $449.96

iv. Records of siting analysis 2 1 2 1 2 0.1 0.2 $224.98

v. Records of persons who have reviewed 

operating procedures 2 1 2 2 4 0.2 0.4 $449.96

vi. Records of persons who have completed 

operator training 2 1 2 2 4 0.2 0.4 $449.96

vii. Records of persons who meet operator 

qualification criteria 2 1 2 2 4 0.2 0.4 $449.96

viii. Records of monitoring device calibration 2 1 2 2 4 0.2 0.4 $449.96

ix. Records of site-specific documentation 24 1 24 2 48 2.4 4.8 $5,399.50

 F. Train personnel See 3B

 G. Audits N/A

Subtotal for Recordkeeping Requirements 82.8 $8,099.25

TOTAL LABOR BURDEN AND COST (rounded) 798 $78,068
18

Assumptions:

a. There are currently no existing units subject to the standard, and we expect three new sources to become subject over the three-year period of this ICR. We have 

assumed that the average number of respondents that will be subject to the rule will be 1 existing source and one new source. 

b. This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “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. One-time only costs.

d. Cost incurred by a facility regardless of the number of affected units at the plant.

e. Annual cost. Annual costs are not incurred until the second year of operation.

f. Assumed that 10 percent of the facilities (conservatively rounded to one) would not have a qualified operator available for more than two weeks at least once a 

year. Assume that this would require only two corrective action summaries.

g. Assumed that 10 percent of the facilities would have an exceedance during the year. 

h. 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.
19

Table 2: Average Annual EPA Burden and Cost – NSPS for Sewage Sludge Incineration Units (40 CFR Part 60, Subpar LLLL)

(Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant per 

year

(C)

EPA personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Read and Understand Rule Requirements 40 1 40 1 40 2 4 $2,072.90

3. Required Activities

A. Observe stack tests c48 1 48 1 48 2.4 4.8 $2,487.48

B. Excess emissions - Enforcement activities 24 1 24 1 24 1.2 2.4 $1,243.74

C. Create Information N/A

D. Gather Information N/A

E. Report Reviews

i. Review initial notifications d40 2 80 1 80 4 8 $4,145.79

ii. Review initial compliance report 40 1 40 1 40 2 4 $2,072.90

iii. Review annual compliance report 8 0 0 1 0 0 0 $0

iv. Review semi-annual excess emission 

and parameter exceedance report 16 1 16 2 32 1.6 3.2 $1,658.32

v. Review status reports and corrective 

action summary for operators off-site 4 1 4 2 8 0.4 0.8 $414.58

F. Prepare annual summary report e4 1 4 2 8 0.4 0.8 $414.58

Subtotals Labor Burden and cost 280 14 28 $14,510.27

TOTAL LABOR BURDEN AND COST (rounded) 322 $14,510

Assumptions:

a. There are currently no existing units subject to the standard, and we expect three new sources to become subject over the three-year period of this ICR. We have 

assumed that the average number of respondents that will be subject to the rule will be 1 existing source and one new source. 

b. This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial 

rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates are from the 

Office of Personnel Management (OPM) “2010 General Schedule”, which excludes locality rates of pay.

c. Assumes EPA personnel attend 20 percent of the stack tests (conservatively rounded up to one plant). Assume all facilities meet reduced testing requirements, so 

only initial stack test required over three year period.

d. Includes notification of construction and notification of start-up for new units.

e. Assumes four hours per state to write annual summary report.