Burden 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 – NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)
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		Labor Rates:
2. Familiarize with regulatory requirements d	2	1	2	35	70	3.5	7	$9,169.44		Management	$147.40
3. Required activities										Technical	$117.92
A. Initial performance tests c	8	1	8	0	0	0	0	$0		Clerical	$57.02
B. Engineering calculations c	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 c	N/A
B. Notifications for new area sources
(1) Notification of intent to construct/reconstruct c	4	1	4	0	0	0	0	$0
(2) Notification of commencement of construction/reconstruction c	4	1	4	0	0	0	0	$0
(3) Notification of startup c	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 c	2	1	2	0	0	0	0	$0
E. Notification of compliance status c	2	1	2	0	0	0	0	$0
F. Gather information for semi-annual reports	4	2	8	35	280	14	28	$36,677.76
G. Semiannual compliance reports	4	2	8	35	280	14	28	$36,677.76
Subtotal for Reporting Requirements					725			$82,525
5. Recordkeeping requirements
A. Plan activities c	4	1	4	0	0	0	0	$0
B. Implement activities
(1) Record performance tests c	1	1	1	0	0	0	0	$0
(2) Record malfunctions	0.5	2	1	35	35	1.75	3.5	$4,584.72
(3) Continuous parameter monitoring calibration and maintenance	1	12	12	35	420	21	42	$55,016.64
C. Store, file, and maintain records	4	1	4	35	140	7	14	$18,338.88
Subtotal for Recordkeeping Requirements					684			$77,940		70	responses
Total Labor Burden and Cost (rounded) g					1,410			$160,000		20	hrs/response
Total Capital and O&M Cost (rounded) g								$525
Grand TOTAL (rounded) g								$161,000
Assumptions:
a We have assumed that there are 35 existing sources that are subject to the rule, and that no new area sources per year will become subject over the 3 year-period of this ICR.
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 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 This ICR assumes all respondents will take 2 hours to familiarize with the regulatory requirements.
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)
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		Labor Rates:
2. Required activities										Management	$65.71
A. Observe initial performance tests c	8	1	8	0	0	0	0	$0		Technical	$48.75
B. Review initial performance test reports, engineering calculations, and operating parameters c	4	1	4	0	0	0	0	$0		Clerical	$26.38
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	9	72	3.6	7.2	$3,936
TOTAL (rounded) g					83			$3,940
Assumptions:
a We have assumed that there are 35 existing sources that are subject to the rule, and that no new area sources per year will become subject over the 3 year-period of this ICR.
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, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
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.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.