Burden Calculations

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal)
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 (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$148.45
3. Reporting requirements										Technical	$121.46
A. Familiarize with the regulatory requirements c	1	1	1	144	144	7.2	14.4	$19,426.39		Clerical	$60.23
B. Required activities
Initial performance tests d	72	1	72	2	144	7.2	14.4	$19,426.39
Repeat of performance test d, e	72	1	72	0.4	28.8	1.44	2.88	$3,885.28
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/ reconstruction f	2	1	2	2	4	0.2	0.4	$539.62
Notification and demonstration of CMS g	40	1	40	2	80	4	8	$10,792.44
Notification of actual startup	2	1	2	2	4	0.2	0.4	$539.62
Notification of initial performance test	2	1	2	2	4	0.2	0.4	$539.62
Report of performance test	See 3B
Notification of physical or operational change h	2	1	2	2	4	0.2	0.4	$539.62
Semiannual reports	24	2	48	144	6,912	345.6	691.2	$932,466.82
Subtotal for Reporting Requirements					8,424			$988,156
4. Recordkeeping requirements
A. Familiarize with the regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of daily production rate and hours of operation i	0.13	250	32.5	144	4,680	234	468	$631,357.74
Records of operating parameters of CMS j	0.25	250	62.5	144	9,000	450	900	$1,214,149.50
Records of startup, shutdown, and malfunctions k	60	1	60	144	8,640	432	864	$1,165,583.52
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					25,668			$3,011,091		responses	hr/responses
Total Labor Burden and Costs (rounded) l					34,100			$4,000,000		300	114
Total Capital and O&M Cost (rounded) l								$5,240,000
Grand Total (rounded) l								$9,240,000
Assumptions:
a We have assumed that the average number of respondents that are subject to the regulation will be 144, with two sources undergoing reconstruction per year over the three-year period of this ICR.
b This ICR uses the following labor rates for privately-owned sources: $148.45 for managerial, $121.46 for technical, and $60.23 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2020, “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.
c We have assumed that all existing respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 72 hours for each respondent to perform the initial performance test.
e We have assumed that 20 percent of respondents will fail the performance test and will have to repeat it.
f We have assumed that each respondent will take two hours to write the notification of construction/reconstruction report.
g We have assumed that each respondent will take 40 hours to write the notification and demonstration of CMS report.
h We have assumed that each respondent will take 2 hours to write the notification of physical or operational change.
i We have assumed that each respondent will enter information of daily production rate and hours of operation 250 times per year.
j We have assumed that each respondent will take 15 minutes 250 times per year to record the operating parameters of CMS.
k We have assumed that each respondent will take 60 hours to record startup, shutdown, and malfunction information.
l 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 – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year	Cost ($) b
Performance tests										Labor Rates
New or modified facility c	24	1	24	2	48	2.4	4.8	$2,730.46		Technical	$50.72
Repeat performance test										Management	$68.37
New or modified facility d	24	1	24	0.4	9.6	0.48	0.96	$546.09		Clerical	$27.46
Report review
Notification of construction/reconstruction e	2	1	2	2	4	0.2	0.4	$227.54
Notification of physical/operational changes f	2	1	2	2	4	0.2	0.4	$227.54
Notification of actual startup	0.5	1	0.5	2	1	0.05	0.1	$56.88
Notification of performance test	0.5	1	0.5	2	1	0.05	0.1	$56.88
Review of performance test results g	8	1	8	2	16	0.8	1.6	$910.15
Notification of demonstration of CMS	0.5	1	0.5	2	1	0.05	0.1	$56.88
Semiannual reports	8	2	16	144	2,304	115.2	230.4	$131,061.89
TOTAL (rounded) h					2,750			$136,000
Assumptions:
a We have assumed that the average number of respondents will be 144 with two sources undergoing reconstruction per year over the three-year period of this ICR.
b This ICR uses the following labor rates: $68.37 for managerial, $50.72 for technical, and $27.46 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 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 We have assumed that it will take 24 hours for each respondent to perform initial performance test.
d We have assumed that 20 percent of respondents will fail the performance test and will have to repeat it.
e We have assumed that it will take each respondent two hours one-time per year to review notification of construction/reconstruction report.
f We have assumed that it will take each respondent two hours one-time per year to review notification of physical/operation changes.
g We have assumed that it will take each respondent eight hours one-time per year to review the performance test results report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.