Burden Calculations Table

1127t13.xlsx

NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)

Burden Calculations Table

OMB: 2060-0083

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Overview

Table 1
Table 2
Respondents


Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)















122.66 149.84 60.88



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









2. Survey and Studies N/A









3. Acquisition, Installation, and Utilization of Technology and Systems N/A









4. Reporting Requirements










A. Familiarize with regulatory requirements c 1 1 1 828 828 41.4 82.8 $112,806.72


B. Required activities:










i. Initial performance tests d 24 1 24 39 936 46.8 93.6 $127,520.64


ii. Repeat performance tests d 24 1 24 8 192 9.6 19.2 $26,158.08


iii. Reference Method 9 4 1 4 39 156 7.8 15.6 $21,253.44


iv. Monitoring of operations and equipment See 5E









C. Gather existing information See 4B and 5E









D. Write report a, d










i. Notification of actual startup date 2 1 2 17 34 1.7 3.4 $4,632.16


ii. Notification of construction/ reconstruction 2 1 2 17 34 1.7 3.4 $4,632.16


iii. Notification of physical or operational change 2 1 2 22 44 2.2 4.4 $5,994.56


iv. Notification of performance test d 2 1.2 2.4 47 112.8 5.64 11.28 $15,367.87


v. Reports of performance test results See 4B









vi. Periodic reports e N/A









Subtotal for Reporting Requirements


2,687 $318,366


5. Recordkeeping Requirements










A. Familiarize with regulatory requirements See 4A









B. Plan activities See 4B









C. Implement activities See 4B









D. Develop record system N/A









E. Time to enter and transmit information f 1.5 1 1.5 828 1,242.0 62.10 124.2 $169,210.08


F. Time to train personnel N/A









G. Time for audits N/A









Subtotal for Recordkeeping Requirements



1,428 $169,210
responses hr/response
TOTAL LABOR BURDEN AND COST (rounded) g



4,120 $488,000
978 4.21
TOTAL CAPITAL AND O&M COSTS (rounded) g






$0


GRAND TOTAL (rounded) g






$488,000














Assumptions:










a We estimated there are an average of 828 sources subject to the rule, including 811 existing sources that keep records but do not submit reports. In addition, we estimate an average net growth of 17 facilities per year and an average of 22 existing facilities conducting modifications of their facilities.


b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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% to account for the benefit packages available to those employed by private industry.


c We have assumed that all sources will have to familiarize with the regulatory requirements each year.










d We have assumed that a total of 39 new and modified hot mix asphalt facilities would be required to submit notification and conduct a performance test. We have further assumed that about 20 percent of the sources would repeat performance tests due to failure.


e The rule does not require existing sources to submit periodic reports.










f We have assumed that recordkeeping would take sources an average of 1.5 hours a year.










g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.











Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I) (Renewal)












51.23 69.04 27.73
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 (F=Ex0.05) Clerical person-hours per year (G=Ex0.10) Cost, $ b
Review Reports: a, c







Notification of actual startup date 2 1 2 17 34 1.7 3.4 $1,953.47
Notification of construction/ reconstruction 2 1 2 17 34 1.7 3.4 $1,953.47
Notification of physical or operational change 2 1 2 22 44 2.2 4.4 $2,528.02
Notification of performance test 2 1.2 2.4 47 112.8 5.64 11.28 $6,480.92
Reports of performance test results 8 1.2 9.6 47 451 22.56 45.12 $25,923.70
Periodic reports d N/A






TOTAL ANNUAL BURDEN AND COST (rounded) e



777 $38,800









Assumptions:







a We estimated there are an average of 828 sources subject to the rule, including 811 existing sources that keep records but do not submit reports. In addition, we estimate an average net growth of 17 facilities per year and that an average of 22 existing facilities conducting modifications of their facilities.
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 $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c We have assumed that a total of 39 new and modified hot mix asphalt facilities would be required to submit notification and conduct a performance test. We have further assumed that about 20 percent of the sources would repeat performance tests due to failure.
d The rule does not require existing sources to submit periodic reports.







e Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.








Sheet 3: Respondents

Number of Respondents




Respondents That Submit Reports Respondents That Do Not Submit Any Reports

(A) (B) (C) (D) (E)
Year Number of New Respondents 1 Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports Number of Existing Respondents That Are Also New Respondents Number of Respondents (E=A+B+C-D)
1 39 0 794 22 811
2 39 0 811 22 828
3 39 0 828 22 845
Average 39 0 811 22 828
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