Calculation Tables for ICR 2352.04

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)
					103.97	129.93	51.79
Burden Item	(A) Hours per occurrence	(B) No. of occurences per respondent per year	(C) Hours per respondent per year (C=AxB)	(D) Respondents per yeara	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total costs per year ($)b
1. Acquire and install recordkeeping technology and systems c	4	1	4	0	0	0	0	$0
2. Familiarize with regulatory requirements c	2	1	2	75	150	7.5	15	$17,346.83
3. Required activities
A. Initial performance tests d	8	1	8	0	0	0	0	$0
B. Engineering calculations d	8	1	8	0	0	0	0	$0
C. Continuous parameter monitoring e	0	0	0	0	0	0	0	$0
4. Reporting requirements
A. Initial notification that existing facilities are subject to the standard d	N/A
B. Notifications for new area sources
(1) Notification of intent to construct/reconstruct d	4	1	4	0	0	0	0	$0
(2) Notification of commencement of construction/reconstruction d	4	1	4	0	0	0	0	$0
(3) Notification of startup d	4	1	4	0	0	0	0	$0
C. Request for compliance extension f	4	1	4	0	0	0	0	$0
D. Notification of initial performance tests d	2	1	2	0	0	0	0	$0
E. Notification of compliance status d	2	1	2	0	0	0	0	$0
F. Gather information for semi-annual reports	4	2	8	75	600	30	60	$69,387.30
G. Semiannual compliance reports	4	2	8	75	600	30	60	$69,387.30
Subtotal for Reporting Requirements					1,553			$156,121
5. Recordkeeping requirements
A. Plan activities d	4	1	4	0	0	0	0	$0
B. Implement activities
(1) Record performance tests d	1	1	1	0	0	0	0	$0
(2) Record malfunctions	0.5	2	1	75	75	3.75	7.5	$8,673.41
(3) Continuous parameter monitoring calibration and maintenance	1	12	12	75	900	45	90	$104,080.95
C. Store, file, and maintain records	4	1	4	75	300	15	30	$34,693.65
Subtotal for Recordkeeping Requirements					1,466			$147,448
TOTAL ANNUAL BURDEN (rounded)g					3,020			$304,000
Capital and O&M								$1,130
GRAND TOTAL g								$305,000
Assumptions:
a We have assumed that there are 75 existing sources that are subject to the rule, and that no new major sources per year will become subject over the 3 year-period of this ICR.
b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c This ICR assumes all respondents will take 2 hours to familiarize with the regulatory requirements
d This burden item is a one-time activity that applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
e There is no additional burden for monitoring equipment because add-on control devices are not expected to be needed to demonstrate compliance with emission limits and facilities are already equipped with equipment to monitor process and existing control device parameters.
f We have assumed that compliance extensions will not be necessary during the three-year period of this ICR.
g 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 – NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)
					46.67	62.9	25.25
Burden Item	(A) EPA hours per occurrence	(B) No. of occurences per plant per year	(C) EPA hours per plant per year (C=AxB)	(D) Plants per yeara	(E) EPA technical hours per year (E=CxD)	(F) EPA managerial hours per year (F=Ex0.05)	(G) EPA clerical hours per year (G=Ex0.1)	(H) Total cost per year ($)b
1. Read and understand rule requirements c	2	1	2	0	0	0	0	$0
2. Required activities
A. Observe initial performance tests c	8	1	8	0	0	0	0	$0
B. Review initial performance test reports, engineering calculations, and operating parameters c	4	1	4	0	0	0	0	$0
C. Enter and update information into agency recordkeeping system c	1	1	1	0	0	0	0	$0
3. Excess emissions - enforcement activities d	N/A
4. Notification requirements
A. Review initial notification that existing facilities are subject to the standard c	1	1	1	0	0	0	0	$0
B. Notifications for new area sources
(1) Review notification of intent to construct/reconstruct c	4	1	4	0	0	0	0	$0
(2) Review notification of commencement of construction/reconstruction c	2	1	2	0	0	0	0	$0
(3) Review notification of startup c	2	1	2	0	0	0	0	$0
C. Review request for compliance extension e	2	1	2	0	0	0	0	$0
D. Review notification of initial performance tests c	1	1	1	0	0	0	0	$0
E. Review notification of compliance status c	4	1	4	0	0	0	0	$0
5. Review semiannual compliance reports f	4	2	8	19	152	7.6	15.2	$7,956
TOTAL ANNUAL BURDEN (rounded)					175			$7,960
Assumptions:
a We have assumed that there are 75 existing sources that are subject to the rule, and that no new major sources per year will become subject over the 3 year-period of this ICR.
b. This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2014 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. This burden item is a one-time activity that applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
d. We have assumed that no enforcement activities will be conducted over the three-year period of this ICR.
e. We have assumed that compliance extensions will not be necessary during the three-year period of this ICR.
f. We have assumed that EPA technical personnel will review 25% of the semiannual compliance reports.