2403ss01

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EG for Sewage Sludge Incinerators (40 CFR part 60, subpart MMMM) (Proposed Rule)

OMB: 2060-0661

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SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
Emission Guidelines for Existing Sources: Sewage Sludge Incineration (SSI) Units
(Subpart MMMM)
1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a) Title of the Information Collection
"Emission Guidelines for Existing Sources: Solid Sludge Incineration (SSI) Units (Subpart
MMMM)."
1(b) Short Characterization/Abstract
This supporting statement addresses information collection activities imposed by the
Sewage Sludge Incineration (SSI) Unit Emission Guidelines Subpart MMMM. The guidelines do
not apply directly to SSI unit owners and operators. The guidelines can be thought of as model
regulations that States use in developing State plans to implement the emission guidelines. If a
State does not develop, adopt, and submit an approvable State plan, the Environmental Protection
Agency (EPA) must develop a Federal plan to implement the emission guidelines. Whether a SSI
unit is ultimately regulated under a State plan or Federal plan, the full respondent burden for the
first 3 years after promulgation of the emission guidelines is included in this information collection
request (ICR).
The use of the term "Designated Administrator" throughout this document refers to the
person or office designated by each State plan to administer the implementation of the plan, or to
the U.S. EPA Administrator in the event that a State's plan is not approvable and a Federal plan
must be developed. The term "Administrator" alone refers to the U.S. EPA Administrator.
This ICR includes the burden for activities that will be conducted in the first three years
following promulgation of the proposed emission guidelines. These activities include reading the
rule, submitting a control plan, initial stack testing, establishing operating parameters, and
monitoring, recordkeeping, and reporting requirements. We realize, however, 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 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 (owners or operators of SSI units) and the
Designated Administrator (State or Federal Government) that will be imposed by State plans
developed to implement the emission guidelines. Respondents are owners or operators of existing
SSI units.

The requirements described below are the minimum requirements established by the
emission guidelines. Although States may choose to impose more stringent requirements, it is
assumed for this burden estimate that the State plans mirror the emission guidelines.
Sewage Sludge Incinerators are categorized into fluidized bed or multiple hearth units.
For fluidized bed SSI units, 55 units at 40 facilities would be affected by the proposed standards;
for multiple hearth SSI units, 163 units at 73 facilities would be affected. Upon promulgation of
the proposed standards, however, we anticipate that affected SSI units owned by small entities
will be shut down, and that these facilities will use alternative, less expensive means of disposal
instead. The remaining units that would be subject to the regulation over the next three years will
therefore comprise 46 fluidized bed units at 32 facilities and 151 multiple hearth units at 63
facilities. One of these facilities has both a multiple hearth and a fluidized bed unit, so 94 facilities
in all are expected to be subject to the regulation. The cost of this Information Collection Request
(ICR), based on these 197 units at 94 facilities, will be $42.7 million.
The burden to the “Affected Public” for each SSI subcategory may be found in Tables 1 3 in Attachment 2. This rule affects respondents in both the public and private sectors. 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 4 - 7 of Attachment 3.
2.

AUTHORITY/NEED FOR AND USE OF THE COLLECTION
2(a) Need/Authority for the Collection

The EPA is charged under section 111(c) of the Clean Air Act (Act), as amended, to
establish procedures by which:
. . .each State shall submit to the Administrator a plan which (A) establishes standards of
performance for any existing source for any air pollutant. . .to which a standard of
performance would apply if such existing source were a new source, and (B) provides for
the implementation and enforcement of such standards of performance.
The EPA is required under section 129 of the Act, to establish guidelines for existing
stationary sources that reflect the maximum achievable control technology (MACT) for achieving
continuous emission reductions:
Section 129(a)(1) states:
The Administrator shall establish performance standards and other requirements pursuant
to section 111 and this section of each category of solid waste incineration units. Such
standards shall include emissions limitations and other requirements applicable to new
units and guidelines (under section 111(d) and this section) and other requirements
applicable to existing units.
Section 129(a)(2) states:

Standards applicable to solid waste incineration 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.
Section 129(b)(1) states:
Performance standards under this section and section 111 for solid waste incineration units
shall include guidelines promulgated pursuant to section 111(d) and this section applicable
to existing units. Such guidelines shall include, as provided in this section, each of the
elements required by subsection (a) (emissions limitations, notwithstanding any restriction
in section 111(d) regarding issuance of such limitations), subsection (c) (monitoring),
subsection (d) (operator training), subsection (e), (permits), and subsection (h)(4)
(residual risk).
Subpart B of 40 CFR 60 requires State plans to include monitoring, recordkeeping, and
reporting provisions consistent with the emission guidelines. In addition, section 114(a)(1) states
that:
. . . the Administrator may require any person who owns or operates any emission source
or who is 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
or methods, (D) sample such emissions (in accordance with such methods, at such
locations, at such intervals, and in such manner as the Administrator shall prescribe), and
(E) provide such other information, as he may reasonably require.
Certain reports are necessary to enable a Designated Administrator to identify existing
sources subject to the State plan that implements the emission guidelines and to determine if the
standards are being achieved.
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 existing sources subject to the standards; (2) ensure that existing
sources have a control plan to achieve compliance by the final compliance date; (3) ensure that
subpart MMMM is being properly applied; (4) ensure that the emission standards are being
complied with; (5) ensure, on a continuous basis, that the operating parameters established during
the initial performance test are not exceeded.
In addition, records and reports are necessary to enable the Designated Administrator to
identify SSI units that may not be in compliance with the standards. Based on reported
information, the Designated Administrator can decide which SSI units should be inspected and
what records or processes should be inspected at the SSI unit. The records that SSI units
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maintain would indicate to the Designated Administrator whether the personnel are operating and
maintaining control equipment properly and whether they have met the qualification requirements.
3.

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA

The requested recordkeeping and reporting will be required under (40 CFR part 60,
subpart MMMM).
3(a) Nonduplication
This ICR contains reporting and recordkeeping requirements for SSI units, whether
regulated under a State plan or Federal plan. The information collected in the first 3 years
following promulgation of the proposed emission guidelines consists of a control plan as well as
initial and ongoing compliance information. This information collection amends the information
collection requirements currently collected for SSI units by EPA or any other Federal agency.
Other activities, such as performance tests and performance test reports, installation of
monitoring systems and control devices, operator training, and monitoring of operating
parameters, do not typically occur until 4 or 5 years after promulgation. We are estimating these
burdens will occur within the first three years after promulgation of the proposed emission
guidelines to be conservative in our estimates.
In more than 95 percent of the cases, the enforcement of emission guidelines has been
delegated to State air pollution control agencies. In such cases, the reports required by the
standards will be submitted to the appropriate State agency, and not directly to the EPA. Thus,
there is a minimal possibility for the submittal of duplicate information to State agencies and EPA.
In those few cases where State agencies have not developed a State plan or requested delegation
of the Federal plan, Federal enforcement still requires information from the SSI facility. The plant
owner or operator may submit a copy of State or local reports to the Administrator in lieu of the
report required by the standards, 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 has the opportunity to review and comment on the proposed emission
guidelines and ICR during the public comment period.
3(d) Effects of Less Frequent Data Collection

The emission guidelines require a one-time control plan report, a one-time final
compliance report, initial performance tests for ten pollutants, annual performance testing,
continuous operating parameter monitoring, annual operator training, and annual reporting (a
deviation report is required if any of the emission limitations 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
standards.
The control plan is submitted in the first 3 years after promulgation of the emission
guidelines. The one-time control plan will allow the Designated Administrator to determine
whether the owner or operator has an adequate strategy for achieving compliance with the
emission guidelines by the final compliance date. The other activities take place after the
compliance date, which will be in the fifth year after promulgation for most facilities. The final
compliance report notifies the Designated Administrator that the owner or operator has achieved
compliance with the emission guidelines.
Annual reporting allows the submittal of required information and data parameters so that
any potential problems can be identified in a timely fashion. A deviation report is required for
deviations from the operating limits and the emission limitations 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 CFR 1320.5 are being exceeded. This rule requires all records to be maintained
at the source for a period of 5 years. In 40 CFR part 63, subpart A, "General Provisions for
National Emission Standards for Hazardous Air Pollutants for Source Categories," owners or
operators of facilities are required to keep and maintain records for a period of 5 years. These
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. Under section 129 of the
Act, SSI facilities are subject to similar MACT-based regulations, therefore, this 5-year record
retention requirement was adopted for SSI facilities. Furthermore, section 129 requires all SSI
units to obtain title V operating permits under part 70 or 71 permit programs. The title V permit
programs also require records to be retained for 5 years. These 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.
3(f) Confidentiality
All 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 (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
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The reporting or recordkeeping requirements in the standard do not include sensitive
questions.
4.

THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a) Respondents/NAICS Codes

Respondents are owners or operators of SSI units for which construction commences on
or before the date of proposal publication in the Federal Register. 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 distribution of facilities with affected sewage sludge incinerators and the
expectation that small entities will shut down their units, there are 94 existing facilities which will be
affected. Of these, 97 percent are located in the public sector and the remaining 3 percent are located in
the private sector.
4(b) Information Requested
(i) Data Items
Attachment 1, Source Data and Information Requirements, and Tables 1 and 2 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 and 2 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 preparation and submittal of
the final control plan along with initial and ongoing compliance activities. The one-time control
plan will allow the Designated Administrator to determine whether the owner or operator has an
adequate strategy for achieving compliance with the emission guidelines.
Other information collection activities included in the emission guidelines 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. These items

include: performance tests, operating parameter monitoring, operator training, one-time and
periodic reports, and the maintenance of records.
The regulation requires an initial performance test for the following pollutants: PM,
dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, SO2, and fugitive ash. 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. The rule allows the owner or operator to skip two annual
performance tests for PM, HCl, opacity, or fugitive ash emissions if all performance tests over the
previous 3 years show compliance with the emission limit.
To ensure the proper operation of the incinerator, the rule requires that each facility have
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 operators or supervisors must attend an annual refresher course and review sitespecific materials annually.
Following the initial performance test, the owner or operator must submit a report that
documents the performance test and the values for their 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.
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.
Records must be maintained for any incinerator malfunctions, any deviations from the
operating limits, and days for which the minimum amount of operating parameter 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 monitoring device calibration
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.
5.

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 4 through 7 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
Based on Small Business Administration guidelines, approximately 18 small entities are
affected by this rule. The EPA does not expect the standards to have a significant small business
impact.
The EG does not contain any provisions reserved exclusively for the benefit of small
entities. However, the EG 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 PM, HCl, opacity, or fugitive ash 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).
5(d) Collection Schedule
In the first three years following promulgation of the emission guidelines owners or
operators would read the rule and are required to submit a one-time control plan. As discussed
earlier, we also anticipate many of the one-time activities, including: initial performance tests
(PM, dioxins/furans, opacity, HCl, Cd, Pb, Hg, CO, NOx, SO2, fugitive ash), initial operator
training and qualification, and report following initial performance test (includes operating
parameter values) to occur for many facilities within the first three years, but they may occur in
years 4 or 5. These 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 each subcategory of SSI. Continuous
parameter monitoring, with the option of using CEMS, is required. An annual operator training
refresher course and site-specific information review is required.
An annual report is required that includes data on the operating parameters, 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 limitations 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 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
with enforcement programs.
6.

ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 1 and 2 of Attachment 2 document the computation of individual burdens and nonlabor 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 3 of Attachment 2 presents a
summary of the agency burden.
6(a) Estimating Respondent Burden
Upon promulgation of the proposed standards, we anticipate that some of the affected SSI
units will begin to be shut down and facilities will utilize alternative means of disposal instead.
The baseline population of 197 existing SSI units at 94 facilities is based upon our estimates of
how many units would remain operating instead of shutting down.
For the burden estimate, due to the fact that one facility has both a multiple hearth and
fluidized bed unit, the number of fluidized bed facilities is reduced from 32 to 31 in the
calculations to eliminate double counting at the facility level. This has no bearing on unit level
costs.
The average annual burden to industry over the next three years from these recordkeeping
and reporting requirements is estimated to be 21,900 hours. The average annual recordkeeping
hours shown in Tables 1 and 2 of Attachment 2 are 2,000 and the reporting requirement hours are
19,900.
6(b) Estimating Respondent Costs

The information collection activities for sources subject to these requirements are
presented in Tables 1 and 2 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
Technical
Clerical

$92.77 ($43.44 + 110%)*1.017
$57.22 ($26.79 + 110%)*1.017
$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)
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
(B)
Number of
Respondents
(facilities)

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

(E)
Average Annual
Capital/Startup and
O&M Costs

Fluidized Bed

$970,000

$10,700,000

$3,600,000

Multiple Hearth

$860,000

$28,300,000

$9,400,000

Total

$1,830,000

$39,000,000

$13,000,000

(A)
SSI Unit Type

The total capital/startup costs for this ICR are $1.8 million.
The total annualized capital/startup and O&M costs for this ICR are $39 million, or an
average of $13 million 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
$285,000.
This cost is based on the average hourly labor rates as follows:
Managerial
Technical
Clerical

$62.27 (GS-13, Step 5, $38.92+ 60%)
$46.21 (GS-12, Step 1, $28.88+ 60%)
$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 4 through 7 of Attachment 3.
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 on the EPA’s SSI database, accounting for expected
closures upon promulgation of the proposed emission guidelines. Industry burden is calculated
based on the number of units and facilities in each subcategory and the anticipated controls and
monitoring that each unit will most likely utilize to comply with the proposed emissions
guidelines.
Additional estimates regarding the respondent universe are included in the industry burden
determination. The EPA estimates that 94 respondents (facilities) will read the rule in year 1 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 94 respondents incur the annual burden associated with
the emission guidelines, such as annual testing and monitoring system operation and maintenance.
Total Annual Responses
(B)
Number of
Respondents
(facilities)

(D)
Average Annual
Number of
Responses

Fluidized Bed

875

292

Multiple Hearth

2509

836

Total

3391

1128

(A)
Unit Type

The number of average annual responses is 1130.
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 emission guidelines is presented in Tables 1 and 2 of Attachment 2. Tables 1.A, 1.B, and
1.C show the costs for Fluidized Bed units in years 1, 2, and 3. Table 1.D summarizes the costs
for the three year period. Similarly, Tables 2.A, 2.B, 2.C, and 2.D show the costs for Multiple
Hearth units. 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 Table 3). A similar approach was taken for estimating annual labor costs. For the first three
years after the adoption of the emission guidelines, it is estimated that industry would expend
21,900 hours annually at a cost of $1.24 million per year to meet the monitoring, recordkeeping,
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and reporting requirements. The annual non-labor costs are estimated at $13 million, which
include the initial and 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 4
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 7 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 6,000 hours at a cost of $285,000 per
year.
(iii) Variations in the annual bottom line
The total respondent costs for years 1, 2, and 3 are $14,800,000, $14,000,000, and
$14,000,000, respectively. The corresponding total respondent hours over this period are 30,000,
18,000, and 18,000 (see Tables 1 through 3 of Attachment 2). Activities during this period
include reading and understanding the rule and developing a control plan. 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 12,000, 3,000, and 3,000 total hours in labor, respectively. The corresponding costs for
each year are $590,000, $130,000, and $130,000 (see Tables 4 through 7 of Attachment 3).
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 19 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;
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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
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 MMMM

Requirement
RECORDKEEPING
5-year retention of records.

60.5230

Calendar date of each record.

60.5230(a)
60.5230(b)

Records of increments of progress. Includes copies of the final
control plan and any additional notifications.
Records of site-specific information and incinerator operation
procedures.

60.5230(c)(1)

Records of names of persons who have completed review of
the site-specific information and incinerator operating
procedures in 60.5230(c)(1).

60.5230(c)(2)

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

60.5230(c)(2)

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

60.5230(c)(3)

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

60.5230(c)(4)

Records of control device inspections.

60.5230(d)

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

60.5230(e)

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

60.5230(f)

60.5230(g)

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

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

60.5230(h)

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

60.5230(i)

Records of calibration of any monitoring devices.

60.5230(j)

Records of monitoring plan and performance evaluations.

60.5230(k)

Records of less frequent testing.

60.5230(l)

Records of use of bypass stack.

60.5230(m)

REPORTING
Report your increments of progress no later than 10 business
days after the compliance date for the increment:
final control plan including air pollution control
device descriptions, process changes, type of
waste to be burned, and the maximum design
sewage sludge burning capacity
closure notification, if applicable

60.5235(a)

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 site-specific operating limits
documentation of installation of bag leak
detection system for fabric filter
results of air pollution control device inspection

60.5235(b)

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

Requirement
Report the following information annually:
date of report and beginning and ending dates
of reporting period
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
if no deviations 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 §60.5205(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
annual control device inspection results
information on if continuous monitoring
systems malfunctioned or were out of control
if there were no operator training deviations, a
statement that there were no such deviations

60.5235(c)

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

Requirement
If a deviation from operating limits or emission limits occurs,
submit a deviation report that includes the following
information:
date 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,
including the information specified in
§60.5235(e)(3)(viii)

60.5235(d)

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

60.5235(e)

60.5235(f)
Report the following information if a force majeure occurs:
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
60.5235(g)
Submit a notification 1 month prior if you intend to start or
stop use of a CMS
60.5235(g)
Submit a notification 30 days prior if you intend to conduct a
performance test
60.5235(g)
Submit a notification at least 7 days in advance if you intend to
reschedule a performance test

ATTACHMENT 2
TABLES 1, 2, and 3

Tables 1.A – 1.D:
Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Emission Guidelines for Existing Stationary Sources: Sewage
Sludge Incineration Units - Subpart MMMM, Fluidized Bed
Tables 2.A – 2.D:
Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Emission Guidelines for Existing Stationary Sources: Sewage
Sludge Incineration Units - Subpart MMMM, Multiple Hearth
Table 3:

Summary of Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of the Emissions Guidelines for Existing Stationary
Sources: Sewage Sludge Incineration Units - Subpart MMMM - All
Subcategories

ATTACHMENT 3
TABLES 4, 5, 6, and 7

Table 4:

Annual Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for Existing Stationary
Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 1

Table 5:

Table 6:

Table 7:

Summary of Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for Existing Stationary
Sources: Sewage Sludge Incineration Units – Subpart MMMM

Table 1.A - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emissions Guidelines
for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 1, Fluidized Bed

Burden Item

(A)
Respondent

Emission
Testing

Non-Labor

Hours per
Occurrence

Contractor
Hours

Costs
Per

(Technical
hours)

Per
Occurrence

Occurrence

1. Applications

N/A

2. Surveys and Studies

N/A

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

Occurrences
Per
Respondents
Hours
Per
Respondent
Per Year
Per Year
Respondent
Per Year

Per Year
(C=A x B)

(CXD)

Hours
Per Year

(H)
Emission

Total

Hours
Testing
Labor Costs
Per Year Contractor
Per Year

(E x 0.05) (E x 0.1)

Hours Per
Year

Total

Non-Labor
Costs

Responses
Per Year

Footnotes

Per Year

3. Reporting Requirements
A. Read and Understand Rule Requirements

$100

$2,027

$3,100

a,b,i,j

B. Required Activities
1) Initial stack test and report

Incl. in E.

varies

$71,000

40,825

$3,266,000

2) Annual stack test and test report

Incl. in E.

767

$61,350

3) Operator

training and qualification

a) Establish and teach operator qualification course

1,984

198

$129,710

a,b,j

b) Obtain operator qualification

2,232

112

223

$145,924

a,b,j

c) Annual refresher course

Incl. in a.

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

Incl. in B.1

1,840

184

$120,296

a) Initial capital costs

$20,935

$963,000

a,d

b) Annualized capital and O&M costs

$12,680

506

$33,081

$583,300

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
5) Continuous parameter monitoring (including CEMS)

$6,015

b) Fugitive Ash Emissions

$3,007

$4,053

a) Pollutants, opacity

$7.50

368

$24,059

$345

b) Fugitive Ash Emissions

$6,015

2) Notification of initial CMS Demonstration

b,j

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report for site-specific parameter petition
6) Report of initial stack test

Incl. in 3.B.5
14

a,f

$7.50

$2,092

$4,184

$7.50

192

$12,553

$60

7,541

377

754

40,825

$493,016

$3,852,805

Incl. in 3.B.1

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

435

Burden Item
4.

(A)
Respondent

Emission
Testing

Non-Labor

Hours per
Occurrence

Contractor
Hours

Costs
Per

(Technical
hours)

Per
Occurrence

Occurrence

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

Occurrences
Per
Respondents
Hours
Per
Respondent
Per Year
Per Year
Respondent
Per Year

Per Year
(C=A x B)

(CXD)

Hours
Per Year

(H)
Emission

Total

Hours
Testing
Labor Costs
Per Year Contractor
Per Year

(E x 0.05) (E x 0.1)

Hours Per
Year

Total

Non-Labor
Costs

Responses
Per Year

Footnotes

Per Year

Recordkeeping Requirements
A.

Read Instructions

Plan Activities

N/A

Implement Activities

N/A

Develop Record System

N/A

Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.A

Incl. in 3.B.5
1.5

1.5

$392

Incl. in 3.E

4) Records of persons who have reviewed operating procedures

5) Records of persons who have completed operator training

6) Records of persons who meet operator qualification criteria

0.3

0.6

$392

377

755

40,825

$493,408

$3,852,805

435

Labor

Non-Labor

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

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

Recordkeeping Subtotal
TOTAL:

7,547

Total Hours
Summary of Respondent Burden

8,679

Initial Capital and Startup
Annualized Capital/Start-up and O & M

Total

$493,408 $3,852,805 $4,346,213
$966,100
$3,852,805

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.
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.

Assumed that this required only two corrective action summaries.

Table 1.B - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emissions Guidelines
for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 2, Fluidized Bed

Burden Item

(A)
Respondent

Emission
Testing

Hours per
Occurrence
(Technical
hours)

Contractor
Hours
Per
Occurrence

1. Applications

N/A

2. Surveys and Studies

N/A

Non-Labor

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

(H)
Emission

Total

Costs
Occurrences
Per
Respondents
Hours
Hours
Hours
Testing
Labor Costs
Per
Per
Respondent
Per Year
Per Year
Per Year Per Year Contractor
Per Year
Occurrence Respondent
Per Year
Hours Per
Per Year
(C=A x B)
(CXD)
(E x 0.05) (E x 0.1)
Year

Total

Non-Labor
Costs
Per Year

Responses
Per Year

Footnotes

a,b,i

3. Reporting Requirements
A. Read and Understand Rule Requirements

B. Required Activities
1) Initial stack test and report

Incl. in E.

varies

2) Annual stack test and test report

Incl. in E.

767

$61,350

35,276

$2,822,100

3) Operator

training and qualification

a) Establish and teach operator qualification course

a,b

b) Obtain operator qualification

a,b

c) Annual refresher course

372

$24,321

c,j

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

Incl. in a.
8

248

$16,214

c,j

Incl. in B.1

a) Initial capital costs

a,d

b) Annualized capital and O&M costs

$12,680

506

$33,081

$583,300

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
5) Continuous parameter monitoring (including CEMS)

b) Fugitive Ash Emissions

a) Pollutants, opacity

$7.50

b) Fugitive Ash Emissions

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report for site-specific parameter petition
6) Report of initial stack test

Incl. in 3.B.5
14

a,f

$7.50

1,840

184

$120,296

$345

$2,092

$4,184

$7.50

192

$12,553

$60

3,254

163

325

35,276

$212,740

$3,405,805

Incl. in 3.B.1

220

Burden Item
4.

(A)
Respondent

Emission
Testing

Hours per
Occurrence
(Technical
hours)

Contractor
Hours
Per
Occurrence

Non-Labor

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

(H)
Emission

Total

Non-Labor
Costs
Per Year

Responses
Per Year

Footnotes

Recordkeeping Requirements
A.

Read Instructions

Plan Activities

N/A

Implement Activities

N/A

Develop Record System

N/A

Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.A

Incl. in 3.B.5
1.5

1.5

$392

Incl. in 3.E

4) Records of persons who have reviewed operating procedures

$2,027

5) Records of persons who have completed operator training

$2,027

6) Records of persons who meet operator qualification criteria

$2,027

744

$48,641

843

42.15

84.3

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

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

Recordkeeping Subtotal
TOTAL:

4,097

205
Total Hours

Summary of Respondent Burden

4,712

Initial Capital and Startup
Annualized Capital/Start-up and O & M

410

35,276

Labor

Non-Labor

$55,114

$267,854

$3,405,805

220

Total

$267,854 $3,405,805 $3,673,659
$0
$3,405,805

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.

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.
j 32 facilities have FB units; however one of these facilities also has a MH unit. Facility-specific costs are included for only 31 units here and the facility-specific costs for the facility have both
unit types are incorporated into the MH tables.

Table 1.C - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emissions Guidelines
for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 3, Fluidized Bed

Burden Item

(A)

Emission

Respondent
Hours per
Occurrence
(Technical
hours)

Testing
Contractor
Hours
Per
Occurrence

1. Applications

N/A

2. Surveys and Studies

N/A

(B)

(C)

(D)

(E)

(F)

(G)

(H)

Non-Labor
Number of
Hours
Number of Technical Management Clerical
Emission
Total
Costs
Occurrences
Per
Respondents
Hours
Hours
Hours
Testing
Labor Costs
Per
Per
Respondent
Per Year
Per Year
Per Year Per Year Contractor
Per Year
Occurrence Respondent
Per Year
Hours Per
Per Year
(C=A x B)
(CXD)
(E x 0.05) (E x 0.1)
Year

Total
Non-Labor
Costs
Per Year

Total
Footnotes
Responses
Per Year

3. Reporting Requirements
A. Read and Understand Rule Requirements

a,b,i

B. Required Activities
1) Initial stack test and report

Incl. in E.

varies

2) Annual stack test and test report

Incl. in E.

767

$61,350

35,276

$2,822,100

3) Operator

training and qualification

a) Establish and teach operator qualification course

a,b

b) Obtain operator qualification

a,b

c) Annual refresher course

372

$24,321

c,j

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

Incl. in a.
8

248

$16,214

c,j

Incl. in B.1

a) Initial capital costs

a,d

b) Annualized capital and O&M costs

$12,680

506

$33,081

$583,300

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
5) Continuous parameter monitoring (including CEMS)

b) Fugitive Ash Emissions

a) Pollutants, opacity

$7.50

b) Fugitive Ash Emissions

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report for site-specific parameter petition
6) Report of initial stack test

Incl. in 3.B.5
14

a,f

$7.50

1,840

184

$120,296

$345

$2,092

$4,184

$7.50

192

$12,553

$60

3,254

163

325

35,276

$212,740

3,405,805

Incl. in 3.B.1

220

Burden Item
4.

(A)

Emission

Respondent
Hours per
Occurrence
(Technical
hours)

Testing
Contractor
Hours
Per
Occurrence

(B)

(C)

(D)

(E)

(F)

(G)

(H)

Total
Non-Labor
Costs
Per Year

Total
Footnotes
Responses
Per Year

Recordkeeping Requirements
A.

Read Instructions

Plan Activities

N/A

Implement Activities

N/A

Develop Record System

N/A

Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.A

Incl. in 3.B.5
1.5

1.5

$392

Incl. in 3.E

4) Records of persons who have reviewed operating procedures

$2,027

5) Records of persons who have completed operator training

$2,027

6) Records of persons who meet operator qualification criteria

$2,027

744

$48,641

843

42.15

84.3

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

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

Recordkeeping Subtotal
TOTAL:

4,097

205
Total Hours

Summary of Respondent Burden

4,712

Initial Capital and Startup
Annualized Capital/Start-up and O & M

410

35,276

Labor

Non-Labor

$55,114

$267,854

$3,405,805

220

Total

$267,854 $3,405,805 $3,673,659
$0
$3,405,805

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.

Assumed that this required only two corrective action summaries.

Table 1.D - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Emissions Guidelines for Existing Stationary Sources: Sewage Sludge
Incineration Units - Subpart MMMM - Fluidized Bed

Year
1
2
3
Total
Average

Non-Labor
Testing
(Annualized
Contractor
Capital/Startup
Hoursa
Labor Costs and O&M) Costs Total Costs
Total Hours

Technical
Hours

Management
Hours

Clerical
Hours

7,547
4,097
4,097

377
205
205

755
410
410

8,679
4,712
4,712

40,825
35,276
35,276

$493,408
$267,854
$267,854

$3,852,805
$3,405,805
$3,405,805

$4,346,213
$3,673,659
$3,673,659

15,741
5,247

787
262

1,574
525

18,102
6,034

111,378
37,126

$1,029,116
$343,039

$10,664,415
$3,554,805

$11,693,531
$3,897,844

Table 2.A - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emissions Guidelines
for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 1, Multiple Hearth

Burden Item

(A)
Respondent

Emission
Testing

Non-Labor

Hours per
Occurrence

Contractor
Hours

Costs
Per

(Technical
hours)

Per
Occurrence

Occurrence

1. Applications

N/A

2. Surveys and Studies

N/A

(B)
Number of

(D)
Number of

(E)
(F)
Technical Management

(G)
Clerical

(H)
Emission

Total

Hours
Per Year

Testing
Contractor

Labor Costs
Per Year

Non-Labor
Costs

Responses
Per Year

(CXD)

(E x 0.05)

(E x 0.1)

Hours Per
Year

Occurrences
Per
Respondents
Hours
Per
Respondent Per Year
Per Year
Respondent
Per Year

Per Year
(C=A x B)

Footnotes

Per Year

3. Reporting Requirements
A. Read and Understand Rule Requirements

$100

$4,119

$6,300

a,b,i

B. Required Activities
1) Initial stack test and report

Incl. in E.

varies

$58,785

151

110,956

$8,876,500

151

2) Annual stack test and test report

Incl. in E.

767

$61,350

3) Operator

training and qualification

a) Establish and teach operator qualification course

4,032

202

403

$263,604

a,b

b) Obtain operator qualification

4,536

227

454

$296,555

a,b

c) Annual refresher course

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

Incl. in B.1

151

6,040

302

604

$394,883

151

$5,662

151

$855,000

151

a,d

$1,974

151

1,661

166

$108,593

$298,000

c,e

5) Continuous parameter monitoring (including CEMS)
a) Initial capital costs
b) Annualized capital and O&M costs
C. Create Information

Incl. in 3.B

D. Gather Information

Incl. in 3.E

E. Report Preparation
1) Notification of initial performance test
5) Continuous parameter monitoring (including CEMS)

151

302

$19,744

151

b) Fugitive Ash Emissions

151

$9,872

151

126

$8,238

a) Pollutants, opacity

$7.50

151

1,208

121

$78,977

$1,133

151

b) Fugitive Ash Emissions

151

302

$19,744

151

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report for site-specific parameter petition
6) Report of initial stack test

Incl. in 3.B.5
14

$7.50

$3,661

a,f

Incl. in 3.B.1

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

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

112

$7,322

$7.50

336

$21,967

$105

18,925

946

1,893

110,956

$1,237,280

$9,182,038

1,281

Burden Item
4.

(A)
Respondent

Emission
Testing

Non-Labor

Hours per
Occurrence

Contractor
Hours

Costs
Per

(Technical
hours)

Per
Occurrence

Occurrence

(B)
Number of

(D)
Number of

(E)
(F)
Technical Management

Occurrences
Per
Respondents
Hours
Per
Respondent Per Year
Per Year
Respondent
Per Year

Per Year
(C=A x B)

(CXD)

(G)
Clerical

(H)
Emission

Total

Hours
Per Year

Testing
Contractor

Labor Costs
Per Year

Non-Labor
Costs

Responses
Per Year

(E x 0.05)

(E x 0.1)

Hours Per
Year

Footnotes

Per Year

Recordkeeping Requirements
A.

Read Instructions

Plan Activities

N/A

Implement Activities

N/A

Develop Record System

N/A

Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.A

Incl. in 3.B.5
1.5

1.5

$686

Incl. in 3.E

4) Records of persons who have reviewed operating procedures

5) Records of persons who have completed operator training

6) Records of persons who meet operator qualification criteria

10.5

0.525

1.05

$686

18,936

947

1,894

110,956

$1,237,966

$9,182,038

1,281

Labor

Non-Labor

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

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

Recordkeeping Subtotal
TOTAL:

Total Hours
Summary of Respondent Burden

21,776

Initial Capital and Startup
Annualized Capital/Start-up and O & M

$1,237,966 $9,182,038

Total
$10,420,004

$861,300
$9,182,038

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.

Assumed that this required only two corrective action summaries.

Table 2.B - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emissions Guidelines
for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 2, Multiple Hearth

Burden Item

(A)
Respondent

Emission
Testing

Hours per
Occurrence
(Technical
hours)

Contractor
Hours
Per
Occurrence

1. Applications

N/A

2. Surveys and Studies

N/A

Non-Labor

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

(H)
Emission

Total

Non-Labor
Costs
Per Year

Responses
Per Year

Footnotes

a,b,i

3. Reporting Requirements
A. Read and Understand Rule Requirements

B. Required Activities
1) Initial stack test and report

Incl. in E.

varies

2) Annual stack test and test report

Incl. in E.

767

$61,350

151

115,798

$9,263,850

151

3) Operator

training and qualification

a) Establish and teach operator qualification course

a,b

b) Obtain operator qualification

a,b

c) Annual refresher course

756

$49,426

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

Incl. in a.
8

504

$32,951

Incl. in B.1

a) Initial capital costs

a,d

b) Annualized capital and O&M costs

$1,974

151

1,661

166

$108,593

$298,000

151

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
5) Continuous parameter monitoring (including CEMS)

b) Fugitive Ash Emissions

a) Pollutants, opacity

$7.50

b) Fugitive Ash Emissions

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report for site-specific parameter petition
6) Report of initial stack test

Incl. in 3.B.5
14

$7.50

151

6,040

302

604

$394,883

$1,133

151

$3,661

a,f

Incl. in 3.B.1

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

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

112

$7,322

$7.50

336

$21,967

$105

9,465

473

947

115,798

$618,803

$9,563,088

614

Burden Item
4.

(A)
Respondent

Emission
Testing

Hours per
Occurrence
(Technical
hours)

Contractor
Hours
Per
Occurrence

Non-Labor

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

(H)
Emission

Total

Non-Labor
Costs
Per Year

Responses
Per Year

Footnotes

Recordkeeping Requirements
A.

Read Instructions

Plan Activities

N/A

Implement Activities

N/A

Develop Record System

N/A

Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.A

Incl. in 3.B.5
1.5

1.5

$686

Incl. in 3.E

4) Records of persons who have reviewed operating procedures

$4,119

5) Records of persons who have completed operator training

$4,119

6) Records of persons who meet operator qualification criteria

$4,119

1,512

151

$98,852

Recordkeeping Subtotal

1711.5

85.575

171.15

$111,895

TOTAL:

11,177

1,118

115,798

$730,698

$9,563,088

Labor

Non-Labor

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

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

559
Total Hours

Summary of Respondent Burden

12,853

Initial Capital and Startup
Annualized Capital/Start-up and O & M

Total

$730,698 $9,563,088 $10,293,785
$0
$9,563,088

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.

Assumed that this required only two corrective action summaries.

0
614

Table 2.C - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the Emissions Guidelines
for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM - Year 3, Multiple Hearth

Burden Item

(A)
Respondent

Emission
Testing

Non-Labor

Hours per
Occurrence

Contractor
Hours

Costs
Per

(Technical
hours)

Per
Occurrence

Occurrence

1. Applications

N/A

2. Surveys and Studies

N/A

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

Occurrences
Per
Respondents
Hours
Per
Respondent Per Year
Per Year
Respondent
Per Year

Per Year
(C=A x B)

(CXD)

Hours
Per Year

(E x 0.05) (E x 0.1)

(H)
Emission

Total

Testing
Labor Costs
Contractor
Per Year
Hours Per
Year

Total

Non-Labor
Costs

Responses
Per Year

Footnotes

Per Year

3. Reporting Requirements
A. Read and Understand Rule Requirements

a,b,i

B. Required Activities
1) Initial stack test and report

Incl. in E.

varies

2) Annual stack test and test report

Incl. in E.

767

$61,350

151

115,798

$9,263,850

151

3) Operator

training and qualification

a) Establish and teach operator qualification course

a,b

b) Obtain operator qualification

a,b

c) Annual refresher course

756

$49,426

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

Incl. in a.
8

504

$32,951

Incl. in B.1

a) Initial capital costs

a,d

b) Annualized capital and O&M costs

$1,974

151

1,661

166

$108,593

$298,000

151

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
5) Continuous parameter monitoring (including CEMS)

b) Fugitive Ash Emissions

a) Pollutants, opacity

$7.50

b) Fugitive Ash Emissions

2) Notification of initial CMS Demonstration

3) Report of initial performance test

4) Report of initial CMS demonstration
5) Report for site-specific parameter petition
6) Report of initial stack test

Incl. in 3.B.5
14

$7.50

151

6,040

302

604

$394,883

$1,133

151

$3,661

a,f

Incl. in 3.B.1

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

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

112

$7,322

$7.50

336

$21,967

$105

9,465

473

947

115,798

$618,803

9,563,088

614

Burden Item
4.

(A)
Respondent

Emission
Testing

Non-Labor

Hours per
Occurrence

Contractor
Hours

Costs
Per

(Technical
hours)

Per
Occurrence

Occurrence

(B)
Number of

(D)
Number of

(E)
(F)
(G)
Technical Management Clerical

Occurrences
Per
Respondents
Hours
Per
Respondent Per Year
Per Year
Respondent
Per Year

Per Year
(C=A x B)

(CXD)

Hours
Per Year

(E x 0.05) (E x 0.1)

(H)
Emission

Total

Testing
Labor Costs
Contractor
Per Year
Hours Per
Year

Total

Non-Labor
Costs

Responses
Per Year

Footnotes

Per Year

Recordkeeping Requirements
A.

Read Instructions

Plan Activities

N/A

Implement Activities

N/A

Develop Record System

N/A

Record Information
1) Records of operating parameters
2) Records of exceedances of the operating parameters
3) Records of stack tests

Incl. in 3.A

Incl. in 3.B.5
1.5

1.5

$686

Incl. in 3.E

4) Records of persons who have reviewed operating procedures

$4,119

5) Records of persons who have completed operator training

$4,119

6) Records of persons who meet operator qualification criteria

$4,119

1,512

151

$98,852

1711.5

85.575

171.15

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

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

Recordkeeping Subtotal
TOTAL:

11,177

Summary of Respondent Burden

559

1,118

Total Hours

Labor

12,853

$730,698

Initial Capital and Startup
Annualized Capital/Start-up and O & M

$111,895

115,798

$730,698

$9,563,088

Non-Labor

Total

$9,563,088 $10,293,785
$0
$9,563,088

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.

Assumed that this required only two corrective action summaries.

0
614

Table 2.D - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements of the Emissions Guidelines for Existing Stationary Sources: Sewage Sludge
Incineration Units - Subpart MMMM - Multiple Hearth

Year
1
2
3
Total
Average

Non-Labor
Testing
(Annualized
Contractor
Capital/Startup
Hoursa
Labor Costs and O&M) Costs
Total Hours

Technical
Hours

Management
Hours

Clerical
Hours

18,936
11,177
11,177

947
559
559

1,894
1,118
1,118

21,776
12,853
12,853

110,956
115,798
115,798

$1,237,966
$730,698
$730,698

$9,182,038
$9,563,088
$9,563,088

$10,420,004
$10,293,785
$10,293,785

41,289
13,763

2,064
688

4,129
1,376

47,482
15,827

342,553
114,184

$2,699,362
$899,787

$28,308,213
$9,436,071

$31,007,574
$10,335,858

Total Costs

Table 3 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the
Emissions Guidelines for Existing Stationary Sources: Sewage Sludge Incineration Units - Subpart MMMM All Subcategories

Labor Costs

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

Total Costs

Year

Technical
Hours

Management
Hours

Clerical Hours

Total Labor
Hours

Testing
Contractor
Hoursa

26,483

1,324

2,648

30,455

151,781

$1,731,374

$13,034,843

$14,766,217

2
3

15,274
15,274

764
764

1,527
1,527

17,565
17,565

151,074
151,074

$998,552
$998,552

$12,968,893
$12,968,893

$13,967,444
$13,967,444

Total
Average

57,030
19,010

2,851
950

5,703
1,901

65,584
21,861

453,930
151,310

$3,728,477
$1,242,826

$38,972,628
$12,990,876

$42,701,105
$14,233,702

a. Test contractor costs are accounted for in the non-labor category and are not included in burden hours.

Table 4 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the
Emission Guidelines for Existing Stationary Sources: Sewage Sludge Incineration Units Subpart MMMM - Year 1

Burden Item

(A)

(B)

(C)

(D)

(E)

(F)

Number of
Occurrences Per
Year

EPA Hours
Per
Occurrence

Tech Hours
Per Year
(C=AxB)

Management
Hours Per Year
(D=Cx0.05)

Clerical
Hours Per
Year
(E=Cx0.1)

EPA Cost
Per Year
(a,b)

$829

1. Applications

not applicable

2. Read and Understand Rule Requirements

1891

189

$98,007

264

$13,681

$408,361

3. Required Activities
A. Observe initial stack tests

B. Excess emissions -- Enforcement Activities

C. Create Information

not applicable

D. Gather Information

not applicable

E. Report Reviews
1) Review initial stack test report
2) Review annual compliance report
3) Review semi-annual excess emission and parameter exceedance report
4) Review status reports and
site

corrective action summary for operators off-

F. Prepare annual summary report
5. Travel expenses:

(1 person *

197

7880

394

788

352

$18,241

132

$6,841

200

$10,364

$881

per trip

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.

10735

537

1074

$34,721
$591,045

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of
the Emission Guidelines for Existing Stationary Sources: Sewage Sludge Incineration Units Subpart MMMM - Year 2

Burden Item

(A)

(B)

(C)

(D)

(E)

(F)

Number of
Occurrences Per
Year

EPA Hours
Per
Occurrence

Tech Hours
Per Year
(C=AxB)

Management
Hours Per Year
(D=Cx0.05)

Clerical
Hours Per
Year
(E=Cx0.1)

EPA Cost
Per Year
(a,b)

$829

1. Applications

not applicable

2. Read and Understand Rule Requirements

3. Required Activities
A. Observe initial stack tests

B. Excess emissions -- Enforcement Activities

264

$13,681

C. Create Information

not applicable

D. Gather Information

not applicable

E. Report Reviews
1) Review initial stack test report
2) Review annual compliance report
3) Review semi-annual excess emission and parameter exceedance report
4) Review status reports and
site

corrective action summary for operators off-

F. Prepare annual summary report
5. Travel expenses:

(1 person *

197

1576

158

$81,672

352

$18,241

132

$6,841

200

$10,364

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.

2540

per trip

127

254

$0
$131,629

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the
Emission Guidelines for Existing Stationary Sources: Sewage Sludge Incineration Units Subpart MMMM - Year 3

Burden Item

(A)

(B)

(C)

(D)

(E)

(F)

Number of
Occurrences Per
Year

EPA Hours
Per
Occurrence

Tech Hours
Per Year
(C=AxB)

Management
Hours Per Year
(D=Cx0.05)

Clerical
Hours Per
Year
(E=Cx0.1)

EPA Cost
Per Year
(a,b)

$829

1. Applications

not applicable

2. Read and Understand Rule Requirements

3. Required Activities
A. Observe initial stack tests

B. Excess emissions -- Enforcement Activities

264

$13,681

C. Create Information

not applicable

D. Gather Information

not applicable

E. Report Reviews
1) Review initial stack test report
2) Review annual compliance report
3) Review semi-annual excess emission and parameter exceedance report
4) Review status reports and
site

corrective action summary for operators off-

F. Prepare annual summary report
5. Travel expenses:

(1 person *

197

1576

158

$81,672

352

$18,241

132

$6,841

200

$10,364

per trip

127

254

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.

2540

$0
$131,629

Table 7 - Summary of Designated Administrator Burden and Cost of Recordkeeping and
Reporting Requirements of the Emission Guidelines for Existing Stationary Sources:
Sewage Sludge Incineration Units - Subpart MMMM
Technical
Hours

Management
Hours

Clerical
Hours

10,735

537

1,074

12,345

2
3

2,540
2,540

127
127

254
254

15,815
5,272

791
264

1,582
527

Year

Total
Average

Non-Labor
Costs

Total Costs

$591,045

2,921
2,921

$131,629
$131,629

$0
$0

$131,629
$131,629

18,187
6,062

$854,303
$284,768

$0
$0

$854,303
$284,768

Total Hours Labor Costs

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