Burden Calculation Tables

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Overview

# Responses
Table 1
Table 2
O&M Cost

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Sheet 1: # 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 periodic performance test	4.00	1	0	4.00
Report of periodic performance test results	4.00	1	0	4.00
			Total	8
			New Respondents	0
			Existing Respondents	8

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Sheet 2: Table 1

Table 1: Average Annual Respondent Burden and Cost – NESHAP for Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart LLLLL)(Residual Risk and Technology Review Amendments)
					$112.98	$149.35	$54.81
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
1. Applications	N/A
2. Survey and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements										New Respondents	0
A. Familiarization with rule amendments:										Existing Respondents	8
Existing Respondents c	1.33	1	1.33	8	10.67	0.53	1.07	$1,343.24
B. Required activities:
New and Existing Respondents
Periodic 5-year performance testing d	8	1.2	9.6	4	38.4	1.92	3.84	$4,835.66		Respondent Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.”)
C. Gather Existing Information	Included in 5D, 5E									Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
D. Write report										Mgmt.	$71.12	$149.35
Notification of periodic 5-year of performance test d	1.33	1	1.33	4	5.33	0.27	0.53	$672		Tech.	$53.80	$112.98
Reports of periodic 5-year performance test results d	Included in 4B, 5E									Cler.	$26.10	$54.81
Subtotal for Reporting Requirements					63			$6,851
5. Recordkeeping Requirements
A. Read instructions	Included in 4A
B. Plan activities	Included in 4B
C. Implement activities	Included in 4B
D. Develop record system	NA
E. Time to enter and transmit all information into record system
Record of periodic performance tests d	1.33	1	1.33	4	5.33	0.27	0.53	$672
F. Time to train personnel	Included in 4B
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					6			$672
TOTAL LABOR BURDEN AND COST (rounded) e					69			$7,520
CAPITAL AND O&M COST (see Section 6(b)(iii)) e								$88,400
TOTAL COST (rounded) e								$95,900
							9	hr/response
a Assumes an average of 8 respondents per year over the next three years of this ICR and that no new facility per year will become subject to this regulation.
b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 Assumes 4 hours in the first year of this information collection for familiarization with the final rule amendments under the risk and technology review, annualized over the 3 years of this information collection.
d All costs related to periodic testing are shown annualized over the 3 years of this information collection. Assumes that periodic testing will occur once every 5 years, and the first periodic performance test would occur within 3 years of the promulgation date of the final rule amendments. Assumes that the testing and reporting are conducted by an emissions testing contractor, and facility personnel will work on-site to assist the contractor. Assumes an average of 8 respondents would perform the following tests: (1) 4 asphalt roofing manufacturing facilities would conduct an EPA Method 5A test of the PM control device, an EPA Method 25A test of the thermal oxidizer, and an EPA Method 9 opacity test; and (2) 4 asphalt processing facilities would conduct an EPA Method 25A test of the thermal oxidizer and an EPA Method 9 opacity test. Assumes that 3 of the 4 asphalt roofing manufacturing facilities and 1 of the 4 asphalt processing facilities already perform all periodic performance testing under State Agency permits; therefore, this information collection includes the cost for only the 4 remaining facilities not currently required to conduct periodic testing under State Agency permits (1 asphalt roofing manufacturing facility and 3 asphalt processing facilities). Assumes that 20 percent of new respondents will repeat the performance tests due to failure.
e Total cost has been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart LLLLL)(Residual Risk and Technology Review Amendments)

$48.08

$64.80

$26.02

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

Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule

New and Existing Respondents

Hourly Mean Wage

With Fringe & Overhead

Report of periodic 5-Year performance testing c

6.67

1.2

8.00

4

32.00

1.60

3.20

1,725.49

(GS- 12, step 1) - Tech.

30.05

$48.08

TOTAL ANNUAL BURDEN AND COST (rounded) d

37

$1,730

(GS- 13, step 5) - Mgmt.

40.5

$64.80

(GS-6, step 3) - Cler.

16.26

$26.02

Assumptions:

a Assumes an average of 8 respondents per year over the next three years of this ICR and 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 $64.80 (GS-13, Step 5), Technical rate of $48.08 (GS-12, Step 1), and Clerical rate of $26.02 (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) 2017 General Schedule which excludes locality rates of pay.

c The EPA is requiring periodic performance testing once every 5 years, with the first periodic performance test required within 3 years of the promulgation date of the final rule. Assumes 20 hours for periodic performance test report review, annualized over the 3 years of this information collection. We have assumed that 20 percent of periodic performance tests will be repeated due to failure.

d Total cost has been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: O&M Cost

Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)
Periodic 5-Year Test	Cost, Annualized a	Number of Respondents b	Total Cost, Annualized (B X C)
PM control device c	$27,700.00	1	$27,700.00
Thermal oxidizer d	$14,666.67	4	$58,666.67
Opacity Testing e	$500.00	4	$2,000.00
Total			$88,400.00
a Assumes periodic testing of once per 5 years, with the first periodic test required within 3 years of the publication date of the final RTR amendments. Assumes the first periodic performance test would occur in the third year of this information collection, and this cost includes any contractor costs associated with repeat testing.
b Assumes an average of 8 respondents per year would perform the following tests: (1) 4 asphalt roofing manufacturing facilities would conduct an EPA Method 5A test of the PM control device, an EPA Method 25A test of the thermal oxidizer, and an EPA Method 9 opacity test; and (2) 4 asphalt processing facilities would conduct an EPA Method 25A test of the thermal oxidizer and an EPA Method 9 opacity test. Assumes that 3 of the 4 asphalt roofing manufacturing facilities and 1 of the 4 asphalt processing facilities already perform all periodic performance testing under State Agency permits; therefore, this information collection includes the cost for only the 4 remaining facilities not currently required to conduct periodic testing under State Agency permits (1 asphalt roofing manufacturing facility and 3 asphalt processing facilities).
c Assumes the contractor cost for PM control device performance testing using EPA Method 5A at a facility with 7 PM filters is $83,100, based on a cost of $16,500 for first filter and an add-on charge of $11,100 for each additional filter.
d Assumes the contractor cost for total hydrocarbon (THC) performance testing of a thermal oxidizer using EPA Method 25A is $44,000.
e Assumes the contractor cost for opacity testing using EPA Method 9 is $1,500.
5-Year Periodic Testing Costs For Facilities Not Currently Required to Test Under State Permit
Industry Sub-Group	Number of Facilities Not Currently Required to Test Under State Permit a ($)	Average PM Test Cost per Facility ($)	Average VE or Opacity Test Cost per Facility ($)	Average THC Test Cost per Facility ($)	Total Average Test Cost Per Facility ($)	Total Cost for Facilities Not Currently Required to Test Under State Permit a ($)
Asphalt roofing manufacturing facilities	1	$83,100.00	$1,500.00	$55,000.00	$139,600.00	$139,600
Asphalt processing facilities	3	$0.00	$1,500.00	$44,000.00	$45,500.00	$136,500
Total - Asphalt roofing manufacturing facilities and Asphalt processing facilities	4					$276,100
a Includes Hunt Southland Refining Co. - Sandersville, Certainteed Corp. (Oxford, NC),Wynnewood Refining Co., and Valero Refining Co.
Source: Appendix A from memo "Cost Impacts for the Asphalt Processing and Asphalt Roofing Manufacturing Risk and Technology Review Proposal", September 2018
Facility Name	City	State	State Required 5-yr Tests	Asphalt Storage Tanks1	Number of PM Control Devices	Number of Thermal Oxidizers	VE or Opacity Test Cost1 ($)	PM Test Cost2 ($)	THC Test Cost3 ($)	Total Test Cost ($)
Hunt Refining Company	Tuscaloosa	AL	Yes	Yes	0	1	1,500	0	44,000	see footnote 4
Owens-Corning	Minneapolis	MN	Yes	Yes	3	1	1,500	38,700	44,000	see footnote 4
Hunt Southland Refining Co. - Sandersville	Heidelberg	MS	No	Yes	0	1	1,500	0	44,000	45,500
Certainteed Corp.	Oxford	NC	No	Yes	7	2	1,500	83,100	88,000	172,600
Owens-Corning Fiberglass Trumball	Medina	OH	Yes	Yes	4	1	1,500	49,800	44,000	see footnote 4
Wynnewood Refining Co.	Wynnewood	OK	No	Yes	0	1	1,500	0	44,000	45,500
Valero Refining Co.	Ardmore	OK	No	Yes	0	1	1,500	0	44,000	45,500
Certainteed Corp.	Shakopee	MN	Yes	Yes	3	1	1,500	38,700	44,000	see footnote 4
TOTAL COST OVER 5-YR PERIOD										309,100
1 Cost of opacity testing using EPA Test Method 9 is estimated to be $1,500. For each facility that has asphalt storage tanks, it was assumed that the facility would have at least one Method 9 test.
2 Cost of PM performance testing using EPA Test Method 5A is estimated to be $16,500 for first filter and an add-on charge of $11,100 for each additional filter.
3 Cost of THC performance testing using EPA Test Method 25A is estimated to range from $16,200 (concentration) to $44,000 (efficiency). We chose to be conservative and apply the higher cost of $44,000.
4 Costs not included for these facilities because they are already required to test every 5-yrs by the State permitting agency and will not incur additional testing costs with the new testing requirements.