Burden Calculations Tables

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Overview

Table 1
Table 2
Capital and O&M
# Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart LLLLL) (Renewal)
					$117.92	$147.40	$57.02			Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.”)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. Of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical person-hour / year (E=CxD)	Management person-hour / year (Ex0.05)	Clerical (Ex0.1)	Cost, $ b		Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
1. Applications	N/A									Mgmt.	$70.19	$147.40
2. Survey and Studies	N/A									Tech.	$56.15	$117.92
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									Cler.	$27.15	$57.02
4. Reporting Requirements										New Respondents	0
A. Familiarization with regulatory requirements										Existing Respondents	8
New Respondents	25	1	25	0	0	0	0	$0
Existing Respondents	1	1	1	8	8	0.4	0.8	$1,047.89
B. Required activities:
New Respondents c, d
i. Initial performance test	24	1	24	0	0	0	0	$0
ii. Repeat of initial performance test e	24	0.2	4.8	0	0	0	0	$0
iii. Startup, shutdown, malfunction plan	40	1	40	0	0	0	0	$0
New and Existing Respondents
iv. Monitoring of operating parameters and equipment: f	Included in 5E
C. Gather Existing Information	Included in 5D, 5E
D. Write report c, d
i. Notification of compliance status	4	1	4	0	0	0	0	$0
ii. Notification of intent to construct a major source and review application	4	1	4	0	0	0	0	$0
iii. Notification of initial construction/ reconstruction a	4	1	4	0	0	0	0	$0
iv. Notification of actual startup	4	1	4	0	0	0	0	$0
v. Notification of performance test	4	1	4	0	0	0	0	$0
vi. Reports of performance test results	Included in 4B, 5E
vii. Semiannual compliance reports d	12	2	24	8	192	9.6	19.2	$25,149.40
viii. Startup, shutdown, malfunction report g	8	1	8	1	8	0.4	0.8	$1,047.89
Subtotal for Reporting Requirements					239			$27,245
5. Recordkeeping Requirements
A. Read instructions	Included in 4A
B. Plan activities	10	1	10	0	0	0	0	$0
C. Implement activities	Included in 4B
D. Develop record system h	NA
E. Time to enter and transmit all information into record system i
i. Record performance tests	4	1	4	0	0	0	0	$0
ii. Record operating parameters	1	365	365	8	2,920	146	292	$382,480.43
iii Record malfunctions	2	1	2	1	2	0.1	0.2	$261.97
iv. Continuous parameter monitoring calibration and maintenance	4	5	20	8	160	8	16	$20,957.83
v. Store, file, and maintain records	20	1	20	8	160	8	16	$20,957.83
F. Time to train personnel	16	1	16	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,728			$424,658
TOTAL LABOR BURDEN AND COST (rounded) j					3,970			$452,000
TOTAL CAPITAL AND O&M COST j								$20,000
TOTAL COST (rounded) j								$472,000
									234	hr/response
Assumptions:
a There is an average of 8 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facility per year will become subject to this regulation.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from “column 1, Total Compensation. “ The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
c New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices and preparation of the startup, shutdown and malfunction (SSM) plans. There are no new respondents anticipated over the next three-year period of this ICR, therefore, there is no anticipated burden associated with these activities.
d We have assumed that the initial performance tests and reports are conducted by an emissions testing contractor, however, facility personnel will also work on-site to assist the contractor.
e We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, this requirement does not apply.
f Monitoring and recordkeeping of operations for respondents with add-on control devices include: 1) specific operating parameters for each control device established during the performance test, 2) start-up, shutdown, and malfunctions of equipment, and 3) work practices.
g We have assumed that one respondent with add-on controls per year will have at least one startup, shutdown or malfunction (SSM) event that is not managed according to the SSM plan.
h We have assumed that new respondents already have the technology and recordkeeping systems in place to monitor its daily operations and to comply with existing regulations.
i We have assumed that it takes respondents the following approximate times to meet recordkeeping requirements: 1) one hour per day for recording operating parameters, 365 days per year; 2) four hours per year to calibrate and provide maintenance to continuous parameter monitors five times per year; and 3) and 16 hours per year to train new employees on add-on control devices, continuous parameter monitoring technology and requirements, and review and implementation of startup, shutdown, and malfunction plans.
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 – NESHAP for Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart LLLLL)(Renewal)
					$48.75	$65.71	$26.38			Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. Of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b		Labor Type	Hourly Mean Wage	With Fringe & Overhead
New Respondents: c										(GS- 12, step 1) - Tech.	30.47	$48.75
i. Notification of compliance status	4	1	4	0	0	0	0	$0		(GS- 13, step 5) - Mgmt.	41.07	$65.71
ii. Notification of intent to construct a major source and review application	4	1	4	0	0	0	0	$0		(GS-6, step 3) - Cler.	16.49	$26.38
iii. Notification of start of construction	2	1	2	0	0	0	0	$0		New Respondents	0
iv. Notification of actual startup	2	1	2	0	0	0	0	$0		Existing Respondents	8
v. Notification of initial performance test and test plan	4	1	4	0	0	0	0	$0
New and Existing Respondents
i. Report of performance test results including operating parameters	20	1	20	0	0	0	0	$0
ii. Review of semiannual compliance reports	8	2	16	8	128	6.4	12.8	$6,998.53
iii. Review of startup, shutdown, malfunction reports d	4	1	4	1	4	0.2	0.4	$218.70
TOTAL ANNUAL BURDEN AND COST (rounded) e					152			$7,220
Assumptions:
a There is an average of 8 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facility per year will become subject to this regulation.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5), Technical rate of $48.75 (GS-12, Step 1), and Clerical rate of $26.38 (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule which excludes locality rates of pay.
c New respondents are required to conduct performance test for add-on control equipment, submit initial notifications and prepare startup, shutdown and malfunction (SSM) plans. There are no new respondents anticipated over the next three-year period of this ICR, therefore, there is no anticipated burden associated with these activities.
d Sources are required to submit SSM reports if there is an occurrence that is not managed according to the SSM plan. We have assumed that one respondent with add-on controls per year will have at least one SSM event that is not managed according to the SSM plan.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and 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	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M
PM control device	$7,000	0	$0	$5,000	4	$20,000
Thermal oxidizer	$25,000	0	$0	NA	0	$0
Photocopy / postage				$15	8	$120
Total			0			$20,000
NA – not applicable; EPA assumes that all facilities subject to the standard have or will obtain add-on control devices that are already equipped with continuous parameter monitoring equipment. This monitoring equipment is required not only for compliance purposes but also to operate the control equipment.
a The estimated contractor cost for initial performance tests of a PM control device using EPA Method 5A is $7,000. The ongoing cost for replacement filters and data collection system maintenance is $5,000.
b The PM limit applies only to asphalt roofing manufacturing facilities, and there are four existing asphalt roofing manufacturing facilities, with no new asphalt roofing manufacturing facilities projected for the three years of this information collection.
c The estimated contractor cost for initial performance tests of a thermal oxidizer, using EPA Method 25A is $25,000.
d The photocopying and postage cost is $7.50 per semiannual report, for a total of $15 per respondent per year.

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Sheet 4: # Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Notification of compliance status	0	1	0	0
Notification of intent to construct a major source and review application	0	1	0	0
Notification of initial construction/ reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of performance test and test plan	0	1	0	0
Report of performance test results	0	1.2	0	0
Report of semiannual compliance reports	8	2	0	16
Report of startup, shutdown, malfunction	1	1	0	1
			Total	17
			New Respondents	0
			Existing Respondents	8