Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge Treatment Plants (40 CFR Part 60, Subpart O) (Renewal)
					120.27	141.06	58.67
Burden Items	(A) Person hours per Occurrence	(B) Number of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Number of respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total costs per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c, d	1	1	1	86	86	4.3	8.6	$11,454.34
B. Required Activities
i. Initial performance test d	72	1	72	0.4	28.8	1.44	2.88	$3,835.87
ii. Demonstration of monitoring system	See 3B(i)
iii. Repeat of performance test e	72	1	72	0.08	5.76	0.29	0.58	$767.17
C. Create Information	See 3B
D. Gather Existing Information	N/A
E. Write Report
i. Notification of construction/ reconstruction d	2	1	2	0.4	0.8	0.04	0.08	$106.55
ii. Notification of physical and operational changes f	2	1	2	0.4	0.8	0.04	0.08	$106.55
iii. Notification of demonstration of CMS d	40	1	40	0.4	16	0.8	1.6	$2,131.04
iv. Notification of actual startup d	2	1	2	0.4	0.8	0.04	0.08	$106.55
v. Notification of initial performance test d	2	1	2	0.4	0.8	0.04	0.08	$106.55
vi. Performance test report	See 3B
vii. Semiannual reports of excess emissions g	40	2	80	86	6,880	344	688	$916,347.20
Subtotal for Reporting Requirements					8,073			$934,962
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 3A
B.  Plan Activities	See 4E
C. Implement Activities	See 4E
D.  Develop Record System	N/A
E.  Time to Enter Information
i. Record of daily production rate and hours of operation h	8	1	8	86	688	34.4	68.8	$91,634.72
ii. Records of startup, shutdown and malfunction	8	1	8	86	688	34.4	68.8	$91,634.72
iii. Records of performance test data d, i	80	1	80	0.4	32	1.6	3.2	$4,262.08
Subtotal for Recordkeeping Requirements					1,619			$187,532		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) j					9,690			$1,120,000		174	56
CAPITAL AND O&M COST (rounded) j								$3,050,000
GRAND TOTAL (rounded) j								$4,170,000
Assumptions:
a This ICR assumes that there are 170 existing units at 86 facilities (respondents) and that 1.2 new, modified or reconstructed units will be constructed over the next three years (0.4 per year)
b This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are the United States Department of Labor, Bureau of Labor Statistics, June 2019, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rate has been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c This ICR assumes all existing facilities will have to re-familiarize with regulatory requirements each year
d Assume that this is a one-time-only cost.
e Assume that 20 percent would have to repeat the performance testing due to failure.
f Assume that 0.4 facility will have a physical or operational change.
g Assume that it will take 40 hours to write semiannual reports.
h Assume that it will take eight hours per year to record daily gathering of monitoring data (which have been automatically recorded).
i Assume that it will take 80 hours per year to record performance test data.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Sewage Sludge Treatment Plants (40 CFR Part 60, Subpart O) (Renewal)
					49.44	66.62	26.75
Activity	(A) EPA hours per occurrence	(B) No of occurrences per Plant per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Costs per Year b
Initial Performance Test c	24	1	24	0.4	9.6	0.48	0.96	$532.28
Repeat initial performance test
Retesting preparation c, d	24	1	24	0.08	1.92	0.10	0.19	$106.46
Report Review
Notification of construction/ reconstruction c	2	1	2	0.4	0.8	0.04	0.08	$44.36
Notification of physical and operational changes e	2	1	2	0.4	0.8	0.04	0.08	$44.36
Notification of actual startup c	0.5	1	0.5	0.4	0.2	0.01	0.02	$11.09
Initial test c	0.5	1	0.5	0.4	0.2	0.01	0.02	$11.09
Repeat performance test	8	1	8	0.4	3.2	0.16	0.32	$177.43
Semiannual reports f	8	2	16	86	1,376	68.8	137.6	$76,293.70
TOTAL LABOR BURDEN and COST (rounded) g					1,600			$77,200
Assumptions:
a This ICR assumes that there are 170 existing units at 86 facilities (respondents) and that 1.2 new, modified or reconstructed units will be constructed over the next three years (0.4 per year)
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $66.62 for Managerial (GS-13, Step 5, $41.64 x 1.6), $49.44 for Technical (GS-12, Step 1, $30.90 x 1.6) and $26.75 Clerical (GS-6, Step 3, $16.72 x 1.6). These rates are from the Office of Personnel Management (OPM) "2019 General Schedule" which excludes locality rates of pay.
c Assume that this is a one-time-only cost.
d Assume that 20 percent would have to repeat the performance testing due to failure.
e Assume that 0.4 source will have a physical or operational change.
f Assume that it will take eight hours to review semiannual reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.