Burden Calculations Table

---

Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

---

Sheet 1: Summary

ICR Summary Information
Hours per Response	66
Number of Respondents	103
Total Estimated Burden Hours	12,000
Total Estimated Costs	$5,250,000
Annualized Capital O&M	$3,810,000
Total Annual Responses	182
Form Number	Not Applicable

---

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Sewage Sludge Treatment Plants (40 CFR Part 60, Subpart O) (Renewal)
					123.94	157.61	62.52
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	103	103	5.15	10.3	$14,221.47
B. Required Activities
i. Initial performance test d	72	1	72	2	144.0	7.2	14.4	$19,882.44
ii. Demonstration of monitoring system	See 3B(i)
iii. Repeat of performance test e	72	1	72	0.4	28.8	1.44	2.88	$3,976.49
C. Create Information	See 3B
D. Gather Existing Information	N/A
E. Write Report
i. Notification of construction/ reconstruction d	2	1	2	2	4	0.2	0.4	$552.29
ii. Notification of physical and operational changes f	2	1	2	2	4	0.2	0.4	$552.29
iii. Notification of demonstration of CMS d	40	1	40	2	80	4	8	$11,045.80
iv. Notification of actual startup d	2	1	2	2	4	0.2	0.4	$552.29
v. Notification of initial performance test d	2	1	2	2	4	0.2	0.4	$552.29
vi. Performance test report	See 3B
vii. Semiannual reports of excess emissions g	40	2	80	103	8,240	412	824	$1,137,717.40
Subtotal for Reporting Requirements					9,904			$1,189,053
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														old:	new
i. Record of daily production rate and hours of operation h	8	1	8	103	824	41.2	82.4	$113,771.74						86	103
ii. Records of startup, shutdown and malfunction	8	1	8	103	824	41.2	82.4	$113,771.74						170	204
iii. Records of performance test data d, i	80	1	80	2	160	8	16	$22,091.60						1.97674418604651
Subtotal for Recordkeeping Requirements					2,079			$249,635		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) j					12,000			$1,440,000		182	66
CAPITAL AND O&M COST (rounded) j								$3,810,000
GRAND TOTAL (rounded) j								$5,250,000
Assumptions:
a This ICR assumes that there are 204 existing units at 103 facilities (respondents) and that 2 new, modified or reconstructed units will be constructed per year over the next three years.
b This ICR uses the following labor rates: Executive, Administrative, and Managerial: $157.61 ($75.05+ 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
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 2 facilities 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.

---

Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Sewage Sludge Treatment Plants (40 CFR Part 60, Subpart O) (Renewal)
					52.37	70.56	28.34
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	2	48	2.4	4.8	$2,819.14
Repeat initial performance test:
Retesting preparation c, d	24	1	24	0.4	9.6	0.48	0.96	$563.83
Attend retesting	24	1	24	0.4	9.6	0.48	0.96	$563.83
Report Review:
Notification of construction/ reconstruction c	2	1	2	2	4	0.2	0.4	$234.93
Notification of physical and operational changes e	2	1	2	2	4	0.2	0.4	$234.93
Notification of actual startup c	0.5	1	0.5	2	1	0.05	0.1	$58.73
Initial test c	0.5	1	0.5	2	1	0.05	0.1	$58.73
Repeat performance test	8	1	8	0.4	3.2	0.16	0.32	$187.94
Semiannual reports f	8	2	16	103	1,648	82.4	164.8	$96,790.34
TOTAL LABOR BURDEN and COST (rounded) g					1,990			$102,000
Assumptions:
a This ICR assumes that there are 204 existing units at 103 facilities (respondents) and that 2 new, modified or reconstructed units will be constructed per year over the next three years.
b This cost is based on the following labor rates: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM), 2022 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.
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 2 sources 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.

---

Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M b	Total O&M, (E X F)
Particulate Matter	$100,000	2	$200,000	$35,000	103	$3,605,000
Total (rounded) b			$200,000			$3,610,000		$3,810,000
a New respondents include sources with constructed, reconstructed and modified affected facilities.
b Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

---

Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/ reconstruction	2	1	N/A	2
Notification of physical and operational changes	2	1	N/A	2
Notification of demonstration of CMS	2	1	N/A	2
Notification of actual startup	2	1	N/A	2
Notification of initial performance test	2	1	N/A	2
Semiannual report of excess emissions	103	2	N/A	172
			Total	182

---

Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	2	103	0	2	103
2	2	103	0	2	103
3	2	103	0	2	103
Average	2	103	0	2	103
a New respondents include sources with constructed and reconstructed affected facilities.